1. sports
2. table tennis and ping-pong

A Probabilistic Risk Assessment for Children Who
Contact CCA-Treated Playsets and Decks
Draft Preliminary Report
November 10, 2003
Prepared by:
W. Dang, J. Chen
U. S. Environmental Protection Agency
Office of Pesticide Programs, Antimicrobials Division
and
N. Mottl, L. Phillips, P. Wood, S. McCarthy,
R. Lee, M. Helmke, M. Nelson, and K. Coon
Versar, Inc.
DISCLAIMER
This report has undergone internal EPA review through the Office of Research and Development (ORD) and the Office of
Pesticide Programs (OPP). Some of the statutory provisions described in this report contain legally binding requirements.
However, this report does not substitute for those provisions or regulations, nor is it regulation itself. Any decisions regarding
a particular risk reduction process and remedy selection decision will be made based on the statute and regulation, and EPA
decision makers retain the discretion to adopt approaches on a case-by-case basis.
TABLE OF CONTENTS
1.0 EXECUTIVE SUMMARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1
2.0 INTRODUCTION AND BACKGROUND . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1
2.1
2.2
Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-2
Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-2
2.2.1 Regulatory History of CCA . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-2
2.2.2 Current Development of CCA Issue . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-4
2.2.2.1 CPSC Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-5
2.2.2.2 Updated International Actions and Activities . . . . . . . . . . . . . . . . . . . . 2-6
2.2.2.3 Updated State Actions and Activities . . . . . . . . . . . . . . . . . . . . . . . . . 2-8
2.2.3 Use Profile of CCA . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-11
2.2.4 Overview of CCA Chemistry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-12
2.2.4.1 Speciation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-13
2.2.4.2 Fixation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-13
2.2.4.3 Leaching . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-14
2.2.4.4 Environmental Fate . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-18
2.2.5 CCA Use and Potential Exposures to Components of CCA . . . . . . . . . . . . . 2-19
2.2.6 Probabilistic Risk Assessment versus Deterministic Risk Assessment . . . . . . 2-20
2.2.7 EPA and OPP Regulatory Approach to PRA . . . . . . . . . . . . . . . . . . . . . . . . 2-22
3.0 EXPOSURE ASSESSMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-1
4.0 HAZARD ASSESSMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-1
4.1
4.2
4.3
4.4
4.5
4.6
Arsenic . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Chromium . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Summary Tables . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Early-Life Exposures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Relative Bioavailability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Dermal Absorption . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
4-2
4-3
4-4
4-5
4-6
4-7
5.0 RISK CHARACTERIZATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-1
5.1
5.2
5.3
5.4
Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-1
Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-3
5.2.1 Noncancer Effects . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-4
5.2.2 Carcinogenic Effects . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-22
Risk Reduction Assuming 0.01% Dermal Absorption Rate . . . . . . . . . . . . . . . . . . . . 5-28
Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-37
i
TABLE OF CONTENTS (CONTINUED)
6.0 RISK REDUCTION IMPACTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-1
6.1
6.2
6.3
6.4
Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-1
6.1.1 Application of Sealant and Hand Washing Information to SHEDS-Wood . . . . 6-2
Risk Characterization for Mitigation Measures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-5
6.2.1 Summary of Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-7
6.2.2 Risk Reduction Through the Use of Sealants . . . . . . . . . . . . . . . . . . . . . . . . . 6-8
6.2.3 Risk Reduction Through Hand Washing . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-14
6.2.4 Risk Reduction Through Use of Sealants and Hand Washing . . . . . . . . . . . . 6-17
Comparison of Residue and Soil Risks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-18
Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-24
7.0 UNCERTAINTY IN THE RISK ASSESSMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-1
7.1
7.2
7.3
7.4
7.5
Environmental Media Sampling and Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Chemical Fate . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Toxicity Data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Exposure Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Risk Characterization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
7-1
7-3
7-4
7-5
7-6
8.0 REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-1
ii
LIST OF TABLES
Table 1-1.
Table 1-2.
Table 1-3.
Table 1-4.
Table 2-1.
Table 2-2.
Table 2-3.
Table 3-1.
Table 3-2.
Table 3-3.
Table 3-4.
Table 3-5.
Table 3-6.
Table 3-7.
Table 3-8.
Table 3-9.
Table 3-10.
Table 4-1.
Table 4-2.
Table 5-1.
Table 5-2.
Table 5-3.
Table 5-4.
Table 5-5.
Table 5-6.
Table 5-7.
Table 5-8.
Table 5-9.
Table 5-10.
Definitions of Key Terms Used in the SHEDS-Wood Risk Assessment . . . . . . 1-2
Summary of Risk Assessment Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-6
Arsenic Cancer Risks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-6
Summary of Arsenic Risks Assuming Different Mitigation
Measures for Warm Climate Conditions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-8
International Regulatory Actions and Activities Related to CCA . . . . . . . . . . . 2-7
State Regulatory Actions and Activities Related to CCA . . . . . . . . . . . . . . . 2-10
Comparison of Deterministic and Probabilistic Risk Assessments . . . . . . . . . 2-20
Arsenic ADDs (mg/kg/day) - Playsets and Decks . . . . . . . . . . . . . . . . . . . . . . 3-3
Chromium(VI) ADDs (mg/kg/day) - Playsets and Decks . . . . . . . . . . . . . . . . 3-4
Arsenic ADDs (mg/kg/day) - Playsets Only . . . . . . . . . . . . . . . . . . . . . . . . . . 3-4
Chromium(VI) ADDs (mg/kg/day) - Playsets Only . . . . . . . . . . . . . . . . . . . . . 3-5
Arsenic ADDs (mg/kg/day) - Pica Ingestion . . . . . . . . . . . . . . . . . . . . . . . . . . 3-5
Arsenic LADDs (mg/kg/day) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-5
Arsenic LADDs (mg/kg/day) - Mitigation with Sealant . . . . . . . . . . . . . . . . . . 3-6
Arsenic LADDs (mg/kg/day) - Mitigation with Hand Washing . . . . . . . . . . . . 3-6
Arsenic LADDs (mg/kg/day) - Mitigation with Hand Washing and Sealant . . . 3-7
Arsenic LADDs (mg/kg/day) - Using 0.01% Dermal Absorption . . . . . . . . . . 3-7
Toxicological Endpoints for Assessing Exposures/Risks to Arsenic (V) . . . . . 4-5
Toxicological Endpoints for Assessing Exposures/Risks to Chromium (VI) . . 4-5
Summary of Risk Assessment Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-4
Arsenic Noncancer MOEs - Playset Only . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-6
Chromium (Cr(VI)) Noncancer MOEs - Playset Only . . . . . . . . . . . . . . . . . . . 5-6
Arsenic Noncancer MOEs - Playset and Deck . . . . . . . . . . . . . . . . . . . . . . . . . 5-7
Chromium (Cr(VI)) Noncancer MOEs - Playset and Deck . . . . . . . . . . . . . . . 5-7
Probabilistic Short-Term MOE Distributions and Risk Levels
for Children Exposed to Arsenic in Warm Climates (Based on
Short-term ADDs in Table 18 From SHEDS-Wood Document) . . . . . . . . . . 5-10
Probabilistic Short-term MOE Distributions and Risk Levels for
Children Exposed to Arsenic in Cold Climates (Based on Short-Term
ADDs in Table 19 From SHEDS-Wood Document) . . . . . . . . . . . . . . . . . . . 5-11
Probabilistic Short-Term MOE Distributions and Risk Levels for
Children Exposed to Chromium (VI) in Warm Climate
(Soil Ingestion Only) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-12
Probabilistic Short-Term MOE Distributions and Risk Levels for
Children Exposed to Chromium (VI) in Cold Climate
(Soil Ingestion Only) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-13
Arsenic Noncancer Short-Term MOEs for Pica Children in Warm
Climate (Based on Short-Term ADDs from Table 33 in SHEDS-Wood) . . . . 5-15
iii
LIST OF TABLES (CONTINUED)
Table 5-11.
Table 5-12.
Table 5-13
Table 5-14
Table 5-15.
Table 5-16.
Table 5-17.
Table 5-18.
Table 5-19.
Table 5-20.
Table 5-21.
Table 6-1.
Table 6-2.
Table 6-3.
Table 6-4.
Table 6-5.
Probabilistic Intermediate-Term MOE Distributions and Risk Levels
for Children Exposed to Arsenic in Warm Climates (Based on the ADDs
in Table 16 From The SHEDS-Wood Document) . . . . . . . . . . . . . . . . . . . . . 5-18
Probabilistic Intermediate-Term MOE Distributions and Risk Levels
for Children Exposed to Arsenic in Cold Climates (Based on ADDs
in Table 17 From the SHEDS-Wood Document) . . . . . . . . . . . . . . . . . . . . . 5-19
Probabilistic Intermediate-Term MOE Distributions and Risk Levels
for Children Exposed to Chromium (VI) in Warm Climates
(Soil Ingestion Only) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-20
Probabilistic Intermediate-Term MOE Distributions and Risk Levels
for Children Exposed to Chromium (VI) in Cold Climates
(Soil Ingestion Only) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-21
Arsenic Cancer Risks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-25
Probabilistic Cancer Risk Distributions and Risk Levels for Children
Exposed to Arsenic in Warm Climates (Based on LADDs in Table 14
from the SHEDS-Wood document) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-26
Probabilistic Cancer Risk Distributions and Risk Levels for Children
Exposed to Arsenic in Cold Climates (Based on LADDs in Table 15
from the SHEDS-Wood document) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-27
Arsenic Cancer Risk Assuming 0.01% Dermal Absorption . . . . . . . . . . . . . . 5-31
Probabilistic Cancer Risk Distributions and Risk Levels for Children
Exposed to Arsenic in Warm Climates (Dermal Residue Absorption
Rate = 0.01%) (Based on LADDs in Table 35 from SHEDS-Wood
document) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-32
Probabilistic Cancer Risk Distributions and Risk Levels for Children
Exposed to Arsenic in Cold Climate (Dermal Residue Absorption
Rate = 0.01%) (Based on LADDs in Table 36 From SHEDS-Wood
Document) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-33
Comparison of Arsenic Risks Between Baseline and 0.01% Dermal
Absorption Warm Climate . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-34
Summary of Sealant Studies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-4
Arsenic Mitigation Measures Evaluated . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-6
Summary of Risks Assuming Different Arsenic Mitigation Measures
for Warm Climate Conditions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-7
Cancer Risks Remaining Following Simulated Reduction in Residues
from the Use of Sealants (Warm Climate only) . . . . . . . . . . . . . . . . . . . . . . . . 6-9
Probabilistic Arsenic Cancer Risk Distributions and Risk Ranges
for Children in Warm Climates (reducing deck and playset residue
concentration by 90%) (Based on the LADDs in Table 37 from the
SHEDS-Wood document) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-12
iv
LIST OF TABLES (CONTINUED)
Table 6-6.
Table 6-7.
Table 6-8.
Table 6-9.
Table 6-10.
Table 6-11.
Probabilistic Arsenic Cancer Risk Distributions and Risk Ranges
for Children (Reducing Deck and Playset Residue Concentration by
99.5% in Warm Climates (Based on LADDs in Table 38 from the
SHEDS-Wood document) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Cancer Risks Remaining Following Simulated Reductions from
Hand Washing (Warm Climate Only) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Probabilistic Arsenic Cancer Risk Distributions and Risk Ranges
for Children in Warm Climates (Reducing Exposure by Washing
Hands After Playing on Deck or Playset) (Based on LADDs in Table 39
from the SHEDS-Wood document) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Comparison of Cancer Risks from Combined Mitigation Measures
at 10-6 and 10-5 Risk Levels . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Comparison of Total Risk to Residue Only Risk Under Different
Mitigation Conditions (Playsets and Decks - Warm Climate) . . . . . . . . . . . . .
Comparison of Mitigation Measures to Baseline at the 10-6 Risk
Level (Warm Climate) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
v
6-13
6-14
6-16
6-17
6-22
6-25
LIST OF FIGURES
Figure 1-1
Figure 1-2
Figure 1-3
Figure 5-1.
Figure 5-2.
Figure 5-3.
Figure 5-4.
Figure 5-5.
Figure 5-6.
Figure 5-7.
Figure 5-8.
Figure 5-9.
Figure 5-10.
Arsenic Cancer Risk at the 95% Percentile (Warm Climate) . . . . . . . . . . . . . . 1-9
Arsenic Cancer Risk at the 50% Percentile (Warm Climate) . . . . . . . . . . . . . 1-10
Comparison of Residue Only Risks for Playsets and Decks for
Warm Climate (Maximum Reduction, Moderate Reduction, Baseline) . . . . . 1-11
A Cumulative Distribution Function (CDF) for Cancer Risk . . . . . . . . . . . . . . 5-2
MOE of Short-term ADD for Children Exposed to Arsenic Dislodgeable
Residues and Contaminated Soil from Treated Wood Playsets and
Residential Decks in Warm Climate (separated by children with and
playset only) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-8
MOE of Short-term ADD for Children Exposed to Arsenic Dislodgeable
Residues and Contaminated Soil from Treated Wood Playsets and
Residential Decks in Cold Climate (separated by children with and
playset only) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-9
MOE of Intermediate-term ADD for Children Exposed to Arsenic
Dislodgeable Residues and Contaminated Soil from Treated Wood
Playsets and Residential Decks in Warm Climate (separated by children
with and playset only) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-16
MOE of Intermediate-term ADD for Children Exposed to Arsenic
Dislodgeable Residues and Contaminated Soil from Treated Wood
Playsets and Residential Decks in Cold Climate (separated by children
with and playset only) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-17
Cancer Risk (Lifetime) for Children Exposed to Arsenic Dislodgeable
Residues and Contaminated Soil from Treated Wood Playsets and
Residential Decks in Warm Climate (separated by children with
and playset only) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-23
Cancer Risk (Lifetime) for Children Exposed to Arsenic Dislodgeable
Residues and Contaminated Soil from Treated Wood Playsets and
Residential Decks in Cold Climate (separated by children with and
playset only) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-24
Comparison of Total Risks from Decks and Playsets for Warm
Climate - No Mitigation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-29
Comparison of Residue and Soil Total Exposures for Warm
Climate - No Mitigation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-30
Cancer Risk from Lifetime LADD for Children Exposed to Arsenic
Dislodgeable Residues and Contaminated Soil from Treated Wood
Playsets and Residential Decks in Warm Climate (Dermal Residue
Absorption Rate = 0.01%) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-35
vi
LIST OF FIGURES (CONTINUED)
Figure 5-11. Cancer Risk from Lifetime LADD for Children Exposed to Arsenic
Dislodgeable Residues and Contaminated Soil from Treated Wood
Playsets and Residential Decks in Cold Climate (Dermal Residue
Absorption Rate = 0.01%) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Figure 6-1
Cancer Risk from Lifetime LADD for Children Exposed to Arsenic
Dislodgeable Residues and Contaminated Soil from Treated Wood
Playsets and Residential Decks in Warm Climate (Reducing Deck
and Playset Residue Concentration by 90%) . . . . . . . . . . . . . . . . . . . . . . . . .
Figure 6-2
Cancer Risk from Lifetime LADD for Children Exposed to Arsenic
Dislodgeable Residues and Contaminated Soil from Treated Wood
Playsets and Residential Decks in Warm Climate (Reducing Deck
and Playset Residue Concentration by 99.5%) . . . . . . . . . . . . . . . . . . . . . . .
Figure 6-3
Cancer Risk from Lifetime LADD for Children Exposed to
Arsenic Dislodgeable Residues and Contaminated Soil from Treated
Wood Playsets and Residential Decks in Warm Climate (Reducing
Deck and Playset Residue Concentration by Washing Hands after
Playing on Deck or Playset) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Figure 6-4
Comparison of Residue & Soil Total Arsenic Risks for Warm Climate
99.5% Reduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Figure 6-5
Comparison of Residue & Soil Total Arsenic Risks for Warm Climate
90% Reduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Figure 6-6
Comparison of Residue and Soil Arsenic Risks for Warm Climate
99.5% Reduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Figure 6-7
Comparison of Residue and Soil Arsenic Risks for Warm Climate
90% Reduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
vii
5-36
6-10
6-11
6-15
6-19
6-20
6-21
6-23
APPENDICES
Appendix A
Appendix B
Appendix C
Appendix D
Appendix E
Appendix F
Appendix G
Hazard Identification and Toxicology Endpoint Selection for Inorganic
Arsenic and Inorganic Chromium
Risk Spreadsheets
Comparison of Total Risks to Risk Reduction Impacts
Comparison of Residue and Soil Risk
Summary of Relative Bioavailability Studies
SAP Report No. 2001-12, FIFRA Scientific Advisory Panel Meeting
Effect of Hand Washing on Risks from Exposure to Residues
viii
AUTHORS, CONTRIBUTORS, AND REVIEWERS
The National Exposure Research Laboratory of Exposure Assessment and Risk
Assessment, Office of Research and Development, and the Antimicrobials Division, Office of
Pesticide Programs, was responsible for the preparation of this document. A number of
individuals have reviewed and/or have been contributing authors of this report including:
The Probabilistic Exposure Assessment portion of this report was developed by
the following individuals:
V.G. Zartarian1, J. Xue1, H. Özkaynak1, W. Dang2
U.S. Environmental Protection Agency
1
Office of Research and Development, National Exposure Research Laboratory
2
Office of Pesticide Programs, Antimicrobials Division
G. Glen, L. Smith, C. Stallings
ManTech Environmental Technology, Inc.
The Probabilistic Risk Assessment portion of this report was developed by the
following individuals:
W. Dang, J. Chen
U.S. Environmental Protection Agency
Office of Pesticide Programs, Antimicrobials Division
N.Mottl, L.Phillips, P.Wood, S.McCarthy, R.Lee, M. Helmke,
M. Nelson, and K.Coon
Versar, Inc.
For General Information Related to this Document Contact:
W. Dang
U.S. Environmental Protection Agency
Office of Pesticide Programs, Antimicrobials Division
Mailcode 7510C
1200 Pennsylvania Avenue, N.W.
Washington, D.C. 20460
ix
Acknowledgments
We would like to thank Jack Housenger, William Jordan, Najm Shamin, Timothy Leighton, Norm
Cook, Nancy Chiu, Doreen Aviado, Siroos Mostaghimi, Tim McMahon, David Miller, Steven
Nako, Greg Schweer, Brenda Foos, Andrew Schulman, Susan Griffin, Timothy Barry, Herman
Gibb, Valerie Zartarian, Jianping Xue, Haluk Özkaynak, Francis Suhre, Elizabeth Margosches,
Deborah Smegal and Bart Suhre of the U.S. Environmental Protection Agency, for assisting with
selection of model inputs and reviewing the preliminary draft report. We would also like to thank
the Consumer Product Safety Commission (CPSC), Michael Dong from CDPR of California
EPA, and Cathy Campbell, John Worgan, Connie Moase, from PMRA of Health Canada, Graham
Glen from ManTech Environmental Technology, Inc. for reviewing the preliminary drafts and
providing valuable comments.
We would also like to thank Doreen Aviado, Norm Cook, Najm Shamin, Steve Malish, and
Siroos Mostaghimi of Antimicrobials Division and Debbie Edwards, Director of Registration of
OPP, US EPA for their support, drafting and reviewing the background documents in 2001.
x
PREFACE
The National Exposure Research Laboratory, EPA’s Office of Research and Development
and the Antimicrobials Division of EPA’s Office of Pesticide Program has prepared this document
to address exposures and risks to children from contact with Chromated Copper Arsenate (CCA)treated wood in playsets and decks, and CCA-contaminated soil around these structures. In
October 2001, OPP presented a proposed deterministic exposure assessment approach specific to
CCA to the FIFRA (Federal Insecticide, Fungicide, and Rodenticide Act) Scientific Advisory
Panel (SAP). One of the primary SAP recommendations was to use a probabilistic model to
predict variability of absorbed doses for the population of interest. This document provides a
probabilistic risk assessment based on exposure results from the model as recommended by the
SAP.
In general, a risk assessment should include hazard identification, hazard assessment,
exposure assessment, and risk characterization. In this document, OPP collaborated with ORD to
develop comprehensive state-of-the-art techniques to complete a complex risk analysis of children
exposed to CCA-treated wood at residential sites.
This report fulfills the following EPA basic guiding principles for assessing risk to CCA:
(1) identifying the population (i.e., children) exposed to CCA-treated playsets and decks as part of
the “problem formulation” phase, (2) gathering sufficient information to develop and model the
exposures, (3) conducting sensitivity analysis, (4) discussing the correlation or dependencies
between the input variables, (5) detailing information for each input and output distribution,
including information on the stability of central tendency and higher end values, (6) comparing the
results of deterministic and probabilistic assessments, and (7) using the best available toxicity
information to combine with the exposure estimates to calculate risks. The current policy,
Conditions for Acceptance and associated principles are not intended to apply to dose-response
evaluations for human health risk assessments until this application has been studied further
(Agency Policy Document, 5/15/1997). Currently, OPP does not have the Guidance to perform
the probabilistic analysis of toxicity endpoints.
Three steps were used by OPP to complete this document. The first step used a
deterministic risk assessment approach. The second used a custom-designed probabilistic model
for wood preservative use exposure scenarios. The third step was the risk analysis based on the
exposure model outputs and the toxicity endpoints recommended by the SAP and other EPA
offices (OW, ORD, OCHP, Superfund and OPP).
This report provides the results of a study that used the output of (1) a probabilistic
exposure assessment for children who come into contact with CCA-treated playsets and decks
based on the Stochastic Human Exposure and Dose Simulation Model for the Wood Preservative
Exposure Scenario (SHEDS-Wood) developed by the ORD; and (2) the toxicity data for arsenic
xi
and chromium to develop probabilistic risk assessment for children who contact CCA-treated
playsets and decks.
There are several other risk assessment reports related to children’s exposure from CCAtreated playsets and decks. These reports have been developed by researchers outside of
EPA/OPP. Additionally, research is ongoing that focuses on dislodgeable arsenic surface residues
and risk reduction options based on the application of sealants. However, this assessment uses
state-of-the-art analyses and is different from previous risk assessments in the available literature.
xii
LIST OF ACRONYMS
ACC
AD
ADD
APVMA
Ar (V)
As
ATSDR
AWPA
AWPI
BF
CAP
CCA
CCA-C
CDF
CDHS
CE
CFA
CHAD
CPSC
Cr
Cr(VI)
Cr(III)
CSIS
Cu
DA
DEC
E
EC
EFH
EMRA
EPA
ERDEM
EWG
FIFRA
FR
FQPA
GI
GM
GSD
HBN
American Chemistry Council
Antimicrobials Division
Average Daily Dose
Australian Pesticides & Veterinary Medicines Authority
Arsenic (V)
Arsenic
Agency for Toxics Substances and Disease Registry
American Wood-Preserver’s Association
American Wood Preservers Institute
Bioavailability Factor
Consumer Awareness Program
Chromated Copper Arsenate
CCA Type C
Cumulative Density Function
California Department of Health Services
Cumulative Exposure
Consumer Federation of America
Consolidated Human Activity Database
Consumer Product Safety Commission
Chromium
Chromium (VI)
Chromium (III)
Consumer Safety Information Sheet
Copper
Dislodgeable Arsenic
Department of Environmental Conservation
New Exposure
European Commission
Exposure Factors Handbook
Environmental Risk Management Authority
Environmental Protection Agency
Exposure Related Dose Estimation Model
Environmental Working Group
Federal Insecticide, Fungicide, Rodenticide Act
Federal Register
Food Quality Protection Act of 1996
Gastrointestinal
Geometric Mean
Geometric Standard Deviation
Healthy Building Network
xiii
HED
HIARC
IPEMA
IRIS
LADD
LD50
LOAEL
MCA
MDEP
MOE
MOEcalc
NAS
NCEA
NCP
NERL
NHANES
NHAPS
NOAEL
NOIC
NRC
OPP
OPPTS
ORD
PBPK
pcf
PD
PDF
PMRA
PND
ppm
Pr
PRA
Q1*
RAG
RB
RED
RME
RPAR
RTI
SA
SAP
Health Effects Division, OPP
Hazard Identification Assessment Review Committee
International Play Equipment Manufacturers Association
Integrated Risk Information System
Lifetime Average Daily Dose
Lethal Dose, 50% Kill
Lowest-Observed-Adverse-Effect Level
Monte Carlo Analysis
Maine Department of Environmental Protection
Margin of Exposure
Calculated MOE
National Academy of Sciences
National Center For Exposure Assessment
National Contingency Plan
National Exposure Research Laboratory
National Health and Nutrition Examination Survey
National Human Activity Pattern Survey
No-Observed-Adverse-Effect Level
Notice of Intent to Cancel
National Resource Council
Office of Pesticide Programs
Office of Prevention, Pesticides, and Toxic Substances
Office of Research and Development
Physiologically-Based Pharmacokinetic
Pounds per cubic foot
Position Document
Probability Density Function
Pest Management Regulatory Agency
Preliminary Notice of Determination
Parts per million
Probability
Probabilistic Risk Assessment
Slope Factor
Risk Assessment Guideline
Relative Bioavailability
Reregistration Eligibility Decision
Reasonably Maximum Exposed Individual
Notice of Rebuttable Presumption Against Registration and Continued
Registration
Research Triangle Institute
Surface Area
Science Advisory Panel
xiv
SCS
SCTEE
SF
SHEDS
SHEDS-Wood
SOPs
TC
TE
USDA
USPIRG
Soil Contact Survey
Scientific Committee on Toxicity, Ecotoxicity and the Environment
Slope Factor
Stochastic Human Exposure and Dose Simulation Model
Stochastic Human Exposure and Dose Simulation Model for the Wood
Preservative Scenario
Standard Operating Procedures
(Dermal) Transfer Coefficient
(Dermal) Transfer Efficiency
U.S. Department of Agriculture
U.S. Public Interest Research Group
xv
1.0 EXECUTIVE SUMMARY
The U.S. Environmental Protection Agency’s (EPA) Office of Pesticide Programs (OPP)
is aware of increased concerns raised by the general public, municipal and state governments, and
state/federal regulatory agencies regarding the safety of young children contacting arsenic and
chromium residues while playing on Chromated Copper Arsenate (CCA) treated wood
playground structures and decks. Because of this concern, OPP’s Antimicrobials Division (AD),
with the recommendation of the Federal Insecticide, Fungicide, Rodenticide Act (FIFRA)’s
Scientific Advisory Panel (SAP) and the assistance of the Office of Research and Development
(ORD), has conducted a probabilistic exposure assessment entitled the Stochastic Human
Exposure and Dose Simulation Model for the Wood Preservative Exposure Scenario (SHEDSWood). SHEDS-Wood provides exposures reported as average daily doses (ADDs) and lifetime
average daily doses (LADDs). Children’s exposures may occur through touching CCA-treated
wood and CCA-contaminated soil near treated wood structures, mouthing hands after touching
CCA-treated wood, and eating CCA-contaminated soil. Since EPA has determined that the
arsenic and chromium components of CCA pose the most significant toxicity concerns in
comparison to copper, which is not a recognized or suspected carcinogen, the Agency focused on
evaluating potential adverse short-term (1-day to 1-month), intermediate-term (1 to 6 months)
noncancer exposure doses for total arsenic and chromium as Cr(VI), and lifetime average cancer
exposure doses from total arsenic. Some of the key terms used in the SHEDS-Wood exposure
report are summarized in Table 1-1.
OPP developed a preliminary deterministic risk assessment (Internal Draft Only) on May
30, 2001 (U.S. EPA, 2001a). In this internal draft, OPP reported on a preliminary exposure and
risk assessment on the chromium and arsenic components of CCA to determine the potential
health risks to children from contact with CCA-treated wood playground structures and CCAcontaminated soil resulting from use of CCA on lumber used in the fabrication of playground
equipment and related structures commonly found in residential settings. The U.S. EPA (2001a)
internal draft report was later revised and incorporated as a preliminary exposure assessment on
September 27, 2001 (U.S. EPA, 2001b), which was later reviewed by the FIFRA SAP (U.S.
EPA, 2001c). The exposure factors used in the U.S. EPA (2001a) assessment were primarily
conservative upper bound estimates for short- and intermediate-term noncancer risk. The mean,
or central tendency exposure factors were used for cancer risk.. The results of the U.S. EPA
(2001a) arsenic cancer risk assessment were comparable to the upper bound estimates in this
probabilistic risk assessment. Using an initial oral arsenic cancer slope factor (Q1*) of 1.5
(mg/kg/day) -1, U.S. EPA (2001a) reported a cancer risk of 2.0E-4 which would be equivalent to
5.0E-4 using the Q 1* of 3.67 (mg/kg/day) -1 identified in this report. The arsenic probabilistic
cancer risks presented in this report were 1.4E-4 for the 95 th percentile, 2.3E-5 for the median,
and 4.2E-5 for the mean. The results for the means in the probabilistic assessment are similar to
the 75th percentile for several exposure scenarios.
1-1
Table 1-1. Definitions of Key Terms Used in the SHEDS-Wood Risk Assessment
Key Term
Population
Definition
OPP’s primary population of interest for this assessment were children in the United States who frequently contact CCA-treated wood residues
and/or CCA-containing soil from public playsets (e.g., at a playground, a school, a daycare center). Children playing on residential playsets
were the secondary focus. SHEDS-Wood also examined a subset of these children who contact CCA-treated wood residues and/or CCAcontaining soil from residential playsets and/or residential decks (i.e., at the child’s own home or at another home). Results from both groups of
children (those who contact public playsets only, and those who contact public and residential playsets) were presented in this report.
The focus of this assessment was on estimating the risk to children from contact with various sources of CCA-treated wood. The primary
population considered in this assessment was children with public playsets. EPA believes that more young children are exposed to CCAtreated public playsets than residential playsets because children spend more time on public playsets at schools and daycare centers. EPA also
believes that children playing on public playsets would affect a larger population of children. More data were available for public playsets than
residential playsets. Further, CPSC and other groups have also focused their review on children exposed to public playsets.
Warm vs.
Cold Scenarios
The SHEDS-Wood report referred to separate ‘warm climate’and ‘cold climate’scenarios. However, the Consolidated Human Activity
Database (CHAD) diaries that were used in SHEDS-Wood were missing specific state locator information. Instead of using geographical
locations, ‘warm climate’and ‘cold climate’were simulated by modifying inputs such as surface area of unclothed skin and time spent on
playsets and decks. See the text and tables (e.g., Table 12) of Zartarian et al. (2003) for more details regarding the assumptions for warm vs.
cold climates.
With and Without
Decks
With or without decks was used to indicate whether or not the population of children examined in the assessment had a residential deck or not.
The term “with deck” was used to indicate that a child was exposed to a residential deck (i.e., at the child’s own home or at another home) and
a playset. The term “without decks” was used to indicate that a child was exposed to a playset only (Zartarian et al., 2003).
Sealant (Moderate
and Maximum
Reduction)
Exposure reductions from sealants was assessed in SHEDS-Wood using two assumed reduction levels: moderate (90% residue reduction) and
maximum (99.5% residue reduction). The use of the sealants reduced the arsenic residue concentrations which resulted in a corresponding
reduction in arsenic exposure. EPA derived the assumed reduction estimates based upon the available literature on sealants and the comments
provided by the FIFRA SAP in their review of sealant data (see Appendix F for more details).
Hand Washing
Hand washing was considered for all the modeled scenarios in SHEDS-Wood. Several different input distributions were used for hand washing
events per day, hand washing removal, etc. In addition, a special analysis was simulated in SHEDS-Wood to estimate the exposure after a
child washes his or her hands after playing on a playset or deck. In addition, exposures were modeled using hand washing in combination with
a moderate reduction in residues because of the use of a sealant and hand washing in combination with a maximum reduction in residues
because of the use of a sealant.
Time Periods
For the CCA assessment presented in this report, three exposure time periods were considered: short-term (represented in SHEDS-Wood by a
15 day averaging time; 1 day to 1 month), intermediate-term (represented in SHEDS-Wood by a 90 day averaging time; 1 to 6 months), and
lifetime (6 years exposure over a 75-year lifetime).
Exposure Pathways
There were eight primary exposure pathways considered in SHEDS-Wood: dermal soil contact near decks; dermal residue contact from decks;
soil ingestion near decks; residue ingestion from decks (via the wood-to-hand-to-mouth pathway); dermal soil contact near playsets; dermal
residue contact from playsets; soil ingestion near playsets; and residue ingestion from playsets (via the wood-to-handto-mouth pathway). Dermal exposure was also computed separately for hands and body, and results were aggregated for decks and playsets, as
well as over all pathways.
As pointed out by CPSC (2003a), it is possible in extreme cases that pre-schoolers may occasionally directly mouth portions of a wood play
structure, although this behavior is not likely to be frequent for most playground users. Inhalation exposure to particulates for children that are
present during sandblasting of CCA-treated surfaces would also be another potential pathway. These less common pathways were not included
into the CCA risk assessment. Other potential sources of exposure not included in this assessment or other related CCA risk assessments
include child exposures to picnic tables, porch railings and uprights, contact with pets and objects that have contacted treated wood, and CCA
residues and soil that are brought indoors from outside.
Soil vs. Residue
Exposure
SHEDS-Wood examined ingestion and dermal exposure routes for children from contact with CCA-contaminated soil and wood residues. Soil
exposure refers to dermal contact with CCA-contaminated soil and soil ingestion. Residue exposure refers to dermal contact with CCA-treated
wood and ingestion for residues from CCA-treated wood via hand-to-mouth contact.
1-2
After review of the September 27, 2001 deterministic exposure assessment, SAP
recommended that a probabilistic assessment be developed to examine the exposure scenarios
U.S. EPA (2001c). In 2002, SHEDS-Wood probabilistic model was presented to the SAP for
review and recommendations from the panel. After incorporation of comments from the SAP, a
draft final report was prepared on September 25, 2003. The probabilistic exposure assessment
present results for absorbed doses (both ADD and LADDs). The results of the draft final
SHEDS-Wood probabilistic exposure assessment were used in this risk assessment. It should be
noted, however, that the existing policy, Agency Policy Document (5/15/97), indicated that the
“Conditions for acceptance and associated principles are not intended to apply to dose-response
evaluations for human health risk assessments until this application has been studied further”.
Currently, OPP does not have the Guidance to perform the probabilistic analysis of toxicity
endpoints. Some of the major findings from the probabilistic assessment include:
?
?
?
?
?
?
?
Children who contact playsets only were found to have lower absorbed doses than
children who contact both playsets and decks by a factor of 2.
Warm climate bounding scenarios yielded higher results than cold climate
scenarios.
For children who contact both playsets and decks, the mean arsenic LADDs were
reduced by a factor of 14 and median arsenic LADDs were reduced by a factor of
17 when residue concentrations were reduced by 99.5%.
For children who contact both playsets and decks, the total mean and median
arsenic LADDs were both reduced by a factor of 1.3 when hand washing was
assumed to occur following exposure.
Children with pica soil ingestion behavior had about 2-3 times higher absorbed
mean doses (totaled over all pathways considered) of arsenic than non-pica
children from CCA-treated playsets and decks. The risks estimated for children
with pica soil ingestion behavior were higher than for non-pica children.
Assuming a mean arsenic dermal absorption rate of 0.01% rather than 3% for
children who contact playsets and decks in warm climates, the mean and median
arsenic LADDs were 30% and 26% lower, respectively.
The most significant exposure route for the population of interest for most
scenarios was residue ingestion via hand-to-mouth contact, followed by dermal
contact, soil ingestion, and dermal soil contact.
Risks that arise from the predicted exposures were quantified in this risk assessment. This
report follows OPP guidance. This risk assessment includes a background chapter on issues
related to children’s exposure to CCA-treated wood and the reasons that EPA conducted a nondietary probabilistic assessment (see Chapter 2.0); describes the arsenic and chromium exposures
generated by the SHEDS-Wood model (see Chapter 3.0); summarizes the arsenic and chromium
toxicity endpoints in a hazard assessment (see Chapter 4.0); characterizes the risks for the
exposures generated by the SHEDS-Wood model (see Chapter 5.0); characterizes the reduction
1-3
impacts for the exposures generated by the SHEDS-Wood model (see Chapter 6.0); and discusses
the uncertainty, strengths, and limitations associated with this risk assessment (see Chapter 7.0).
In addition, the following appendices are provided:
Appendix A
Appendix B
Appendix C
Appendix D
Appendix E
Appendix F
Appendix G
Hazard Identification and Toxicology Endpoint Selection for Inorganic Arsenic
and Inorganic Chromium
Risk Spreadsheets
Comparison of Total Risks to Risk Reduction Impacts
Comparison of Residue and Soil Risk
Summary of Relative Bioavailability Studies
SAP Report No. 2001-12, FIFRA Scientific Advisory Panel Meeting
Effects of Hand Washing on Risks from Exposure to Residues
The goal of this risk assessment is to present the SAP with the calculated arsenic cancer
risks to children (age 1-6) exposed to CCA-treated playsets and decks using a probabilistic risk
analysis. It also identifies methods (e.g., sealants and hand washing) which can reduce the arsenic
cancer risks to children. However, there is no concluding statement regarding the percentiles of
the distribution or point estimates (e.g., mean, 50th , 90th , 95th, etc) at which risk management
decisions will be made. OPP intends to provide recommendations on how risk managers should
interpret the results of this risk assessment, after receiving technical comments from the FIFRA
SAP on evaluating probabilistic risk distributions. OPP will carefully consider the FIFRA SAP’s
comments on this issue.
Noncancer Margins of Exposure (MOEs) and cancer risks to children exposed to CCAtreated playsets and decks and/or CCA-containing soil from these playsets and decks were
calculated from doses generated using OPP/ORD’s SHEDS-Wood model for chromium and
arsenic. The exposure assessment considered children, ages 1 to 6 years old.1 Risks due to
possible exposure to Cr(VI) for the soil ingestion route were estimated, conservatively, by
assuming 10% of total chromium was present as Cr(VI). For chromium, as Cr(VI), the toxicity
value used was 0.5 mg/kg/day (a NOAEL) for noncancer effects. The toxicity value for total
arsenic used in this assessment were 3.67 (mg/kg/day)-1 (slope factor) for cancer effects and 0.05
mg/kg/day (a LOAEL) for noncancer effects. The Agency is currently considering
recommendations by the National Research Council (NRC) and the arsenic slope factor may
change in the final version of this risk assessment. The arsenic carcinogenic risk is a conservative
estimate of the risk because the cancer slope factor is characterized as a upper-bound estimate.
Therefore, the true risks to humans, while not identifiable, may not be likely to exceed the upperbound estimates and in fact may be lower. Noncancer risks were evaluated against OPP’s
1
Exposure durations modeled were short-term (1 day to 1 month), intermediate-term (1
to 6 months), and lifetime (6 years averaged over 75 years).
1-4
guidance for MOE values for arsenic and chromium for short-term and intermediate-term
exposure durations. Lifetime cancer risks from arsenic exposure were compared to EPA/OPP’s
risk range of 10-6 to 10 -4. Risks were found to be greater under warm climate conditions than
cold climate conditions (MOEs were lower for warm climates). Exposure to playsets and decks
had higher risks than exposure to playsets alone. Noncancer MOEs for arsenic were found to be
above EPA/OPP’s guidance MOE of 30 for all exposures, except at the extreme upper end of the
distribution. Cr(VI) risks were found to be above the guidance MOE of 100 for all doses. These
noncancer MOEs are summarized in the upper portion of Table 1-2. Cancer risks exceeded the
upper bound of the risk range, 10 -4, at cumulative percentiles ranging from the 90th for warm
climate conditions and exposure to CCA-treated playsets and decks, to the 99th for cold climate
conditions and exposure to playsets only. Across all exposure scenarios, carcinogenic risks were
found to be less than 10-6 at cumulative percentiles of the 9th and lower, meaning at least 91% of
the simulated population had risks above 10-6. The lower portion of Table 1-2 presents the
cumulative percentiles at the three levels of EPA’s risk range.
Table 1-3 presents the arsenic cancer risks from four points on the cumulative probability
curve: mean, median, 95th percentile, and 99th percentile. Risks at the mean and median were
found to be in the range of 10 -5 to 10 -6. At the 95 th percentile, the risk level for exposure to decks
and playsets under warm climate conditions was at 10-4. Risk levels for other conditions of
exposure at this percentile ranged from approximately 4 x 10-5 to 8 x 10 -5.
The influence of the dermal absorption factor was evaluated. Baseline risks were
determined using a dermal absorption factor of 2 to 3%. Risk levels were also calculated using
the lower arsenic dermal absorption factor of 0.01%. Changing the dermal absorption factor by
approximately two orders of magnitude reduced risk by 26% to 47%, depending on the exposure
scenario and the cumulative percentile of interest.
An analysis comparing the arsenic risks from soil exposure versus residue exposure (i.e.,
contact with CCA treated wood surfaces only) was conducted for both sources of exposure:
playsets alone and playsets with decks. The estimated risks should be viewed as approximations,
however, because residue and soil risks were summed across routes at the quartile level and this
incurs inaccuracies. Residue risks were found to be greater than soil risks. For contact with
playsets only, this difference ranged from a factor of approximately 7 at the 50th percentile to 10
at the 99 th percentile. Differences were larger for playsets and decks. At the 50th percentile,
residue risk for playset and deck exposure was slightly greater than 10-5, and approximately 10-4 at
the 95th percentile. Soil only risk for both playset only exposure, and playset and deck exposure
exceeded 10-5 at the 95 th percentile.
1-5
Table 1-2. Summary of Risk Assessment Results
Noncancer MOEs for Arsenic and Chromium a
Source of
Exposure
Climate
Playset Only
Warm
Cold
Playset and Deck
Warm
Cold
Duration of
Exposure
Arsenic
MOE <30
Chromium
MOE <100
Short &
Intermediate
>99.6th Percentile
None
Short &
Intermediate
>99.6th Percentile
None
a Chromium is represented as Cr(VI) for the soil ingestion route only.
b
Cancer Risks for Arsenic
Source of
Exposure
Cumulative Percentiles at Specified Risk Levels
Climate
Playset Only
Playset and Deck
b
10-6
10-5
10-4
Warm
3rd
47th
97th
Cold
9th
69th
99th
Warm
<1st
23rd
90th
Cold
2nd
49th
97th
Percentiles in this table represent the percent of the simulated population that have risks less than or equal to the stated risk
level; e.g., at 10-6, 3% of the population have risks less than 10-6 and 97% have risks greater than 10-6.
Table 1-3. Arsenic Cancer Risks
Arsenic (Q1*= 3.67 (mg/kg/day)-1)
Mean
Scenario
Median
95%ile
99%ile
Warm
Cold
Warm
Cold
Warm
Cold
Warm
Cold
Playset and
Deck
4.2E-05
2.2E-05
2.3E-05
1.1E-05
1.4E-04
7.8E-05
3.1E-04
1.6E-04
Playset Only
2.3E-05
1.2E-05
1.1E-05
5.4E-06
8.3E-05
4.5E-05
2.4E-04
8.9E-05
1-6
In 2001, the FIFRA SAP recommended that additional research was needed to evaluate
the performance and efficacy of different brands of coatings. EPA recently completed the
protocol to begin additional research on the effectiveness of sealants on weathered CCA-treated
wood. In the SHEDS-Wood exposure assessment, the concentration of wood surface residue
was considered as the key variable based on the sensitivity analysis in the SHEDS-Wood exposure
report. Therefore, using the existing data from Stilwell (1998) and CDHS (1987) (see Chapter
6), EPA assumed two reduction levels: moderate (90% residue reduction) and maximum (99.5%
residue reduction) to assess reductions in exposure, and thus risk, based on the use of sealants.
Different mitigation measures to reduce exposure to arsenic-containing residues and, thus
risk, were evaluated. Many of the recommendations to reduce arsenic concentrations are based on
the activities of the homeowner and can only be considered guidance. The SHEDS-Wood model
quantified exposures based on reduction in the residue concentration resulting from the use of
sealants and/or hand washing. No reduction in soil exposure was considered as part of these
mitigation simulations. Although soil concentrations may be reduced over time with the use of
sealants, it was conservatively assumed that soil concentrations were the same as under baseline
conditions. Results of five different mitigation conditions are summarized in this report. Two of
the mitigation conditions simulated the effect of a hypothetical sealant on reducing exposure to
dislodgeable residues. For moderately effective sealant conditions, the residue concentration was
assumed to be reduced by 90%; for maximally effective sealant conditions, residue concentration
was assumed to be reduced by 99.5%. The other type of mitigation measure simulated was
increasing the frequency of hand washing. This was considered alone and in combination with the
sealant conditions. These different mitigation measures were evaluated for the warm climate
condition only, as that had the greater exposure and, thus, risk. The effect of reducing risk was
considered at the 10-6 risk level. Increasing the frequency of hand washing alone or in
combination with sealants had a minimal effect compared to no mitigation on the cumulative
percentile at the 10-6 risk level. Note that although hand washing may not have had a significant
impact on total risk from both (i.e., from both soil and residues), it did have a significant impact
on the dermal and oral routes from the surface residue pathways. The largest change was for the
maximum reduction assumption for contact with playsets only under warm climate conditions,
where the 10-6 risk level was at the 57th percentile compared to the 3 rd percentile at baseline.
Table 1-4 compares the cumulative percentiles at the three risk levels for the various mitigation
measures considered. Figure 1-1 shows a comparison of carcinogenic risks at the 95th percentile
for baseline to the five different mitigation conditions described. Figure 1-2 shows the same
comparison across baseline and mitigation conditions, but for the 50th percentile.
Figure 1-3 compares the effects of the residue mitigation measures to baseline conditions
for playset and decks exposure. This plot shows the approximate residue only risk for the
maximum and moderate reduction in residue concentration, and baseline conditions. Under the
maximum reduction assumption, residue risks were decreased by over 2 orders of magnitude at
the 95th percentile and by approximately 3 orders of magnitude at the 50th percentile.
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Table 1-4. Summary of Arsenic Risks Assuming Different Mitigation
Measures for Warm Climate Conditions
Mitigation Measure
1. Sealant- moderate reduction
2. Sealant – maximum reduction
3. Hand washing
Cumulative Percentiles at Specified Risk Levels
Risk Level of
Risk Level of Risk Level of
10-6
10-5
10-4
Playset Only
27th
94th
>99th
57th
97th
>99th
5th
59th
>99th
28th
58th
3rd
Playset and Deck
1. Sealant-moderate reduction
10th
2. Sealant-maximum reduction
42th
3. Hand washing
<1st
4. Sealant-moderate + hand washing
10th
5. Sealant-maximum + hand washing
44th
6. Baseline
<1st
4. Sealant-moderate + hand washing
5. Sealant-maximum + hand washing
6. Baseline
92nd
96th
47th
>99th
>99th
97th
80th
94th
28th
84th
93rd
23rd
>99th
>99th
95th
>99th
>99th
90th
Note: The baseline scenario includes a certain amount of hand washing. Hand washing, as a mitigation scenario, increases the
frequency of this activity over baseline. See Appendix G for more information on hand washing.
1-8
Figure 1-1 Arsenic Cancer Risk at the 95% Percentile (Warm Climate)
1.5E-04
1.4E-04
1.3E-04
Playsets Only
1.2E-04
Playsets and Decks
1.1E-04
1.0E-04
Cancer Risk
9.0E-05
8.0E-05
7.0E-05
6.0E-05
5.0E-05
4.0E-05
3.0E-05
2.0E-05
1.0E-05
0.0E+00
Baseline
Reduction by
90%
Reduction by
99.5%
Hand Washing
Exposure Scenario
1-9
Hand Washing
and 90%
Reduction
Hand Washing
and 99.5%
Reduction
Figure 1-2 Arsenic Cancer Risk at the 50% Percentile (Warm Climate)
1.5E-04
1.4E-04
1.3E-04
Playsets Only
1.2E-04
Playsets and Decks
1.1E-04
1.0E-04
Cancer Risk
9.0E-05
8.0E-05
7.0E-05
6.0E-05
5.0E-05
4.0E-05
3.0E-05
2.0E-05
1.0E-05
0.0E+00
Baseline
Reduction by 90%
Reduction by 99.5%
Hand Washing
Exposure Scenario
1-10
Hand Washing and
90% Reduction
Hand Washing and
99.5% Reduction
Figure 1-3 Comparison of Residue Only Risks for Playsets and Decks for Warm Climate
(Maximum Reduction, Moderate Reduction, Baseline)
100
Cumulative Probability Density
90
Maximum Reduction (99.5%)
80
Moderate Reduction (90%)
70
Baseline (No Mitigation)
60
50
40
30
20
10
0
1.0E-12
1.0E-11
1.0E-10
1.0E-09
1.0E-08
1.0E-07
Carcinogenic Risk
1-11
1.0E-06
1.0E-05
1.0E-04
1.0E-03
A qualitative assessment of uncertainty was conducted. Uncertainty in the risk
characterization was a result of the combined uncertainty of the exposure assessment generated by
SHEDS-Wood and the uncertainty in the toxicological factors. No quantitative evaluation of the
uncertainty in the toxicity factors was conducted. A qualitative evaluation of the toxicity values
showed that they were at the upper end of the range of a theoretical distribution because they
incorporated several conservative assumptions. An in depth uncertainty and sensitivity analyses
of the SHEDS-Wood exposure assessment was performed by Zartarian et al. (2003). For
uncertainty, the two (out of six listed) most critical inputs were: transfer efficiency and residue
concentration. Sensitivity analysis showed that the most influential variables were: transfer
efficiency, residue concentration, fraction of hand mouthed, and amount of hand washing. Total
uncertainty in the exposure assessment was estimated at a factor of 3-4.
Uncertainty was not modeled in this risk assessment. For carcinogenic risks, it is likely
that the uncertainty is asymmetrical around the factor of 3-4 because slope factor accounts for
several conservative assumptions. There is a low probability that the risks are higher, and a
greater probability the risks are lower. For noncancer effects, the uncertainty is also
asymmetrical. The MOE’s are likely to be underestimated (i.e., they could be greater). Again,
this is due to the LOAEL and NOAEL coming from the upper portion of the theoretical
distribution. For chromium, there is the added conservative assumption that 10% of total
chromium is present as Cr(VI). Taken together with the NOAEL, there is a much greater
probability that the Cr(VI) MOEs are larger than those reported, and far lower probability that
they are less than reported.
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2.0 INTRODUCTION AND BACKGROUND
2.1
Introduction
The U.S. Environmental Protection Agency’s (EPA) Office of Pesticide Programs (OPP)
is aware of increased concerns raised by the general public, municipal and state governments, and
state/federal regulatory agencies regarding the safety of children contacting arsenic and
chromium residues while playing on Chromated Copper Arsenate- (CCA-) treated wood
playground structures and decks. Because of this concern, OPP’s Antimicrobials Division (AD),
with the recommendation of the Science Advisory Panel (SAP) and the assistance of the Office of
Research and Development (ORD), has conducted probabilistic assessments to evaluate potential
childhood exposure to arsenic and chromium components of CCA-treated wood in decks, home
playsets and public playground structures, and contaminated soils commonly found in these
settings. This report focuses on the non-dietary assessment of CCA in treated wood.
OPP/AD’s preliminary approach was reviewed by the SAP in 2001, which used a
deterministic exposure assessment methodology for CCA-treated wood. SAP’s primary
recommendation to OPP was that a more comprehensive probabilistic assessment should be
developed to examine the exposure scenarios presented in the deterministic assessment in 2001.
OPP requested the assistance of ORD in developing a model to conduct a probabilistic
exposure assessment for CCA-treated wood. The Stochastic Human Exposure and Dose
Simulation Model for the Wood Preservative Exposure Scenario (SHEDS-Wood), a probabilistic
exposure model developed by the National Exposure Research Laboratory (ORD/NERL), was
used to develop the exposure assessment for children exposed to CCA-treated playsets and decks.
In 2002, SHEDS-Wood was presented to the SAP for model review and for recommendations
from the panel. After incorporation of comments from the SAP, a draft document prepared by
OPP and ORD in 2003, entitled A Probabilistic Exposure Assessment for Children Who Contact
CCA-treated Playsets and Decks Using the Stochastic Human Exposure and Dose Simulation
Model for the Wood Preservative Exposure Scenario (SHEDS-Wood) (Zartarian et al., 2003),
together with this draft risk assessment report, A Probabilistic Risk Assessment for Children Who
Contact CCA-treated Playsets and Decks, are scheduled to be reviewed by the SAP in December
2003. The SHEDS-Wood document provides exposures, reported as average daily doses
(ADDs) and lifetime average daily doses (LADDs); it does not report risk estimates. The
purpose of this report is to provide the results of a risk analysis, conducted by OPP, that uses the
ADDs and LADDs generated by SHEDS-Wood in combination with toxicological endpoints for
CCA (i.e., based on chromium and arsenic) selected by OPP. This document reports on
children’s risks to CCA using the multiple routes, multiple pathways, and dose estimates
developed from the SHEDS-Wood draft document.
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This OPP risk assessment provides background information on issues related to children’s
exposure to CCA-treated wood and the reasons that EPA conducted a non-dietary probabilistic
assessment (see below); describes the exposures generated by SHEDS-Wood (see Chapter 3.0);
summarizes the arsenic and chromium toxicity endpoints for children used in this risk assessment
(see Chapter 4.0); characterizes the risks for the exposures presented in the SHEDS-Wood model
(see Chapter 5.0); characterizes risk reduction impacts for the exposures presented in the
SHEDS-Wood model (see Chapter 6.0); and discusses the uncertainties, strengths, and limitations
of this risk assessment (see Chapter 7.0).
2.2
Background
Chromated Copper Arsenate (CCA) wood preservatives containing chromium (Cr),
copper (Cu), and arsenic (As) as pesticidal compounds, protect wood from deterioration. They
are predominantly used to pressure treat lumber intended for outdoor use in constructing a variety
of residential landscape and building structures, as well as home, school, and community
playground equipment. Children may potentially be exposed to the pesticide residues remaining
on the surfaces of the treated wood structures as well as the residues leached into the surrounding
soil. EPA is aware of increased concerns raised by the general public and state regulatory
agencies regarding the safety of CCA-treated wood for residential applications. The children’s
risk assessment presented herein evaluates exposure routes and pathways anticipated as realistic,
considering activity patterns and behavior of young children near residential playsets, public
playsets, and residential decks. Children’s exposure may occur through touching CCA-treated
wood and CCA-contaminated soil near treated wood structures, mouthing hands after touching
CCA-treated wood, and eating CCA-contaminated soil. Since EPA has determined that the
arsenic and chromium components of CCA pose the most significant toxicity concerns in
comparison to copper, which is not a recognized or suspected carcinogen, the Agency focused on
evaluating potential adverse short-term, intermediate-term, and lifetime exposures and noncancer/cancer risks to children from arsenic and chromium as Cr(VI). The SHEDS-Wood model
developed by ORD was selected by OPP to conduct the probabilistic children’s exposure and
dose assessment for CCA (Zartarian et al., 2003). The exposure doses generated by SHEDSWood were used in conjunction with toxicity data for arsenic and chromium as Cr(VI) to estimate
the risks presented in this report.
2.2.1 Regulatory History of CCA
Regulatory actions involving inorganic arsenical wood preservatives, including CCA,
began nearly 25 years ago. An administrative review process was initiated in 1978 to consider
whether the registration of certain wood preservative chemicals (pentachlorophenol; coal tar,
creosote and coal tar neutral oil; and inorganic arsenicals) should be canceled or modified. A
separate Notice of Rebuttable Presumption Against Registration and Continued Registration
(RPAR) was issued for each heavy-duty wood preservative under consideration. A RPAR is
2-2
issued when the Agency determines that a pesticide meets or exceeds any of the risk criteria
relating to acute and chronic toxic effects, as set forth under the Federal Insecticide, Fungicide,
and Rodenticide Act (FIFRA). Registrants then have the opportunity to submit evidence in
rebuttal of the Agency’s risk presumptions. The RPAR for inorganic arsenicals (43 FR 202) was
published on October 18, 1978, along with a supporting Position Document (PD 1). According
to that document, the risk criteria met or exceeded by inorganic arsenicals were: oncogenicity,
mutagenicity, and fetotoxic/teratogenic effects. The RPAR generated substantial registrant
comments, but these risks remained unrebutted after the RPAR process.
The Agency issued a Preliminary Notice of Determination (PND), concluding the RPAR
process, which was published in the Federal Register of February 19, 1981 (46 FR 13020). This
notice, along with the supporting Position Document (PD 2/3), stated the Agency’s determination
that the wood preservative chemicals continued to exceed the risk criteria which provided the
basis of the RPARs. To reduce the risks, the Agency proposed certain modifications to the terms
and conditions of registration, including certain protective clothing requirements, classifying all
inorganic aresenical wood preservatives as Restricted Use (available to certified applicators only),
and a mandatory program to provide users of treated wood with handling, use and disposal
precautions.
The preliminary determinations described above were submitted to the FIFRA SAP and
the U.S. Department of Agriculture (USDA) for review. Comments were also solicited from
registrants and any other interested persons. The Agency considered the comments received and
made modifications to the proposed decision announced in the PND. A public meeting was
conducted on April 14, 1983 to allow interested persons to comment on the proposed changes.
Their comments were considered in the development of the final determination, which was a
Notice of Intent to Cancel (NOIC), published in the Federal Register of July 13, 1984 (49 FR
136), along with a supporting Position Document (PD 4).
Several trade associations and numerous registrants requested hearings to challenge the
Agency’s determinations in the July 13 NOIC. The Agency published a Federal Register Notice
on October 31, 1984 (49 FR 43772), postponing the effective date of the labeling modifications
for those registrants who filed applications for amended registration in response to the NOIC.
On January 30, 1985, the Agency published an additional Federal Register Notice (50 FR 4269)
announcing that persons other than registrants could continue to sell and distribute existing stocks
of wood preservative products with existing labeling until further notice. Pre-hearing meetings
were held between the Agency and some of the major parties who had requested hearings, during
which alternative, mutually acceptable, mechanisms for achieving the regulatory goals set forth in
the NOIC were discussed. After careful consideration of some of those alternatives, the Agency
concluded that certain changes to the July 13, 1984 NOIC were appropriate and consistent with
the Agency’s goal of protecting the public from unreasonable adverse effects resulting from
pesticide use. An amended NOIC, announcing these changes, was published in the Federal
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Register of January 10, 1986 (51 FR 7). The modifications were mostly minor in scope, with the
exception that the previous mandatory Consumer Awareness Program (CAP) was deleted from
the labeling requirements. The wood preservative industry agreed to a voluntary CAP to educate
consumers on the proper use and precautionary practices for treated wood.
Arsenic, chromium, and chromated arsenical compounds, used as wood preservatives,
were evaluated under the Registration Standards Program in 1988. This program was established
in order to provide a mechanism for pesticide products having the same active ingredient to be
reviewed and brought into compliance with FIFRA. The outcome of the Registration Standard
for arsenic, chromium, and chromated arsenical wood preservatives was as follows:
•
•
•
•
•
•
Classification of inorganic arsenic and hexavalent chromium as Group A
carcinogens;
Acknowledgment that both arsenic and chromium have demonstrated the potential
to cause teratogenic/fetotoxic effects through peritoneal exposure;
Requirement of a reproduction study using a formulated chromated arsenical
product to address the teratogenic/fetotoxic effects unless a metabolism study
demonstrated that blood levels of chromium and arsenic are not increased above
background levels;
Requirement of metabolism data to assess the bioavailability of chromium and
arsenic after exposure to a formulated product;
Requirement of additional ecological effects and environmental fate data; and
Reiteration of label restrictions set forth in the prior NOICs.
Currently, the only remaining use of arsenic acid is for wood preservation. The last
remaining agricultural use of arsenic acid, as a desiccant on cotton, was voluntarily canceled in
1993 (58 FR 86, May 6, 1993). The voluntary cancellation was enacted following a NOIC issued
for the cotton desiccant use of arsenic acid (56 FR 50576, October 7, 1991) due to the cancer
risks to workers. The voluntary cancellation allowed the sale of existing stocks until December
31, 1993, after which they could be lawfully disposed of or sold to the wood preservative industry
for reformulation or repackaging into registered wood preservative products.
2.2.2 Current Development of CCA Issue
On March 17, 2003 EPA granted the voluntary cancellation and use termination requests
affecting virtually all residential uses of CCA-treated wood. Under this action, affected CCA
products cannot be used after December 30, 2003 to treat lumber intended for use in most
residential settings. This transition affects virtually all residential uses of wood treated with CCA,
including play structures, decks, picnic tables, landscaping timbers, residential fencing, patios, and
walkways/boardwalks. This action was proposed in February 2002 by the registrants of CCA
pesticide products that are used to treat wood. Phase-out of the residential uses will reduce the
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potential exposures and risks from arsenic, a known human carcinogen, thereby protecting human
health, especially children's health, and the environment. The current action follows the February
2002 publication of a notice of receipt of voluntary cancellation/use termination requests, which
also provided an opportunity for public comments to be submitted to EPA. A notice of the
cancellation order was published in the Federal Register on April 9, 2003. Consumers may
continue to buy and use the treated CCA wood for as long as it is available, but the transition to
using the new generation treatment products is well underway. The Agency is deferring any
action on two uses involved in the termination requests: (1) wood used in permanent wood
foundations; and (2) wood used in fence posts for agricultural uses. Therefore, these two
products may continue to be treated with CCA at this time. EPA is working with the registrant
community and other stakeholders to ensure that safer, comparable alternatives will be available.
EPA is continuing its work on an ongoing comprehensive reevaluation of CCA-treated wood that
has been underway as part of the Agency's effort to re-evaluate older pesticides to ensure that
they meet current health and safety standards. More information on CCA-treated wood is
available at the following EPA website:
http://www.epa.gov/pesticides/factsheets/chemicals/1file.htm
The Agency is evaluating CCA under the reregistration process within OPP. Once OPP
completes the reregistration review for CCA, the Reregistration Eligibility Decision (RED)
document for Chromated Arsenicals will be released. The RED will include a comprehensive
assessment of the potential human impacts (preliminary focus on occupational and environmental
exposures/risks attributed to the use of CCA-treated wood and related inorganic chromated
arsenical pesticides at the workplace) as well as potential impacts on the environment.
2.2.2.1
CPSC Activities
On March 17, 2003, the U.S. Consumer Product Safety Commission (CPSC) staff held a
Commission Briefing to respond to the petition from the Environmental Working Group (EWG)
and the Healthy Building Network (HBN) to ban the CCA-treated wood being used in
playground equipment and to review the safety of CCA-treated wood for general use (CPSC,
2003a). After briefing the Commissioners and the public on CPSC’s deterministic risk
assessment, CPSC staff recommended denial of the petition based on the actions of EPA (CPSC,
2003a). On November 4, 2003, CPSC voted unanimously that a ban was not necessary because
the wood industry no longer uses CCA-treated wood for playsets. CPSC’s decision was based on
an agreement between CCA manufacturers and the Environmental Protection Agency (EPA) to
phase out CCA treatment of wood for most consumer uses by the end of 2003. More information
on CPSC’s briefing on CCA-treated wood is available at the following website:
http://www.cpsc.gov/cpscpub/prerel/prhtml04/04026.html
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2.2.2.2
Updated International Actions and Activities
The European Commission (EC) has banned the sale of CCA-treated wood for most
residential uses, effective June, 2004 (CPSC, 2003b; APVMA, 2003; EMRA, 2003a). However,
none of the countries banned CCA-treated wood that is already in use (EMRA, 2003a). EC
countries include Germany, Belgium, Luxembourg, France, Portugal, Spain, Italy, Greece,
Austria, the United Kingdom, Ireland, Finland, Sweden, Denmark and The Netherlands (EMRA,
2003a).
The EC published a Marketing and Use Directive on January 6, 2003 stating “labeling
requirements for CCA-treated wood, and banning the sale of CCA-treated wood unless structural
integrity of the wood is needed for human or livestock safety and skin contact by the public is
unlikely. The directive is to take effect by 30 June 2004 and applies only to CCA Type C
preservatives. Situations in which CCA preservatives may not be used include residential or
domestic constructions, where there is a risk of repeated skin contact, and where the wood may
come into contact with intermediate or finished products intended for human consumption. The
directive does not apply to CCA-treated wood already in use” (EMRA, 2003a).
“Restrictions on use of CCA already exist in a number of member states. Germany,
Sweden, Austria, Finland, the Netherlands and Denmark had already initiated voluntary
agreements or regulations restricting the use and marketing of CCA and CCA-treated wood.”
(EMRA, 2003a). However, for the United Kingdom, the Health and Safety Executive
recommended to the government in 1999 to continue using CCA-treated wood with certain
environmental data and occupational requirements (EMRA, 2003a).
Canada’s Pest Management Regulatory Agency (PMRA) has reached an agreement with
industry on the proposed transition away from the use of CCA-treated wood at residential sites.
The PMRA agreement is identical to the voluntary label changes for CCA-treated wood that were
proposed by EPA. Canada’s Consumer Safety Information Sheet can be found at
http://www.ccasafetyinfo.ca. and Fact Sheet information can be found at
http://www.hc-sc.gc.ca/pmra-arla/english/pdf/fact/fs_cca-june2003-e.pdf
In Australia, the Australian Pesticides and Veterinary Medicines Authority (APVMA) has
initiated reconsideration of the registration and associated label approval of products containing
arsenic. It is anticipated that a draft report of APVMA’s review of arsenic will be available for
public comment in mid-2004 (APVMA, 2003).
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Table 2-1. International Regulatory Actions and Activities Related to CCA
International
Community
Summary of Action and Activities
Website Source
USA
EPA
CCA is currently undergoing reregistration
review by EPA. EPA granted the voluntary
cancellation and use termination requests
affecting virtually all residential uses of
CCA-treated wood. Under this action,
affected CCA products cannot be used after
December 31, 2003, to treat lumber intended
for use in most residential settings. EPA
provides public health information on arsenic
in pressure treated wood and provides safety
recommendations for homeowners and
additional information on their website. EPA
is also awaiting results from ongoing work
performing studies regarding the
effectiveness of sealant on wood structures.
Canada
CCA is currently undergoing reregistration review by PMRA in collaboration with EPA.
PMRA granted the voluntary cancellation and use termination requests affecting virtually
all residential uses of chromated copper arsenate (CCA) treated wood. Under this action,
affected CCA products cannot be used after December 31, 2003 to treat lumber intended
for use in most residential settings (Personal Communication, 2003; PMRA, 2003). PMRA
provides public health information on arsenic in pressure treated wood and provides safety
recommendations for homeowners and additional information on their website.
http://www.hc-sc.gc.ca/pmraarla/english/index-e.html
Europe
EC will consider banning the sale of CCA-treated wood. Countries include Germany,
Belgium, Luxembourg, France, Portugal, Spain, Italy, Greece, Austria, the United
Kingdom, Ireland, Finland, Sweden, Denmark and The Netherlands (EMRA, 2003). The
Scientific Committee on Toxicity, Ecotoxicity and the Environment (SCTEE) provided an
assessment of risk to health and the environment of arsenic in wood preservatives in 1998.
SCTEE recommended use of arsenic-based timber treatment to situations where it is
‘absolutely necessary’(APVMA, 2003). EC member countries must publish the provisions
necessary to comply with the directive in June 2003 and apply the provisions by June 2004.
SCTEE provides public health information on arsenic in pressure treated wood and
provides safety recommendations for homeowners and additional information on their
website.
http://www.europa.eu.int
Australia
The APVMA has initiated reconsideration of the registration and associated label approval
of products containing arsenic. The reconsiderations will be made after APVMA has
assessed all data and other information provided to it for this purpose. It is anticipated that a
draft report of APVMA’s review of arsenic will be available for public comment in
mid-2004 (APVMA, 2003). APVMA provides public health information on arsenic in
pressure treated wood and provided safety recommendations for homeowners on their
website.
http://apvma.gov.au
New Zealand
Additional research was commissioned on public health risks related to CCA, particularly
around homes and playgrounds. EMRA has decided against a reassessment of registrations
of CCA. However, EMRA is currently reviewing labeling procedures, disseminating public
health information on CCA, assessing alternatives to CCA, etc. For public CCA-treated
playsets, EMRA is not taking action on existing facilities. However, the government is
working with schools on ways to reduce exposure to CCA (e.g., using coatings) on
publically-maintained playsets (EMRA, 2003b).
http://mfe.govt.nz
CPSC
On March 17, 2003, CPSC held a
Commission Briefing to respond to the
petition from the Environmental Working
Group (EWG) and the Healthy Building
Network (HBN). After briefing the
Commissioners and the public on their
deterministic risk assessment, CPSC
deferred their decision on the petition
pending final EPA action. CPSC provides
public health information on arsenic in
pressure treated wood and provides safety
recommendations for homeowners and
additional information on their website.
2-7
http://www.epa.gov
http://www.cpsc.gov
New Zealand has also commissioned additional research on public health risks related to
CCA, particularly around homes and playgrounds (EMRA, 2003a; APVMA, 2003). Based on an
internal review of public health risks, Environmental Risk Management Authority (EMRA) has
decided against a reassessment of registrations of CCA. However, EMRA is currently reviewing
labeling procedures, disseminating public health information on CCA, assessing alternatives to
CCA, etc. For public CCA-treated playsets, EMRA is not taking action on existing facilities.
However, the government is working with schools on ways to reduce exposure to CCA (e.g.,
using coatings) on publically-maintained playsets (EMRA, 2003b). Table 2-1 summarizes
international regulatory actions and activities related to CCA.
2.2.2.3
Updated State Actions and Activities
In 1987, the California Department of Health Services (CDHS), Health and Welfare
Agency, conducted a research study entitled, Evaluation of Hazards Posed by the Use of Wood
Preservatives on Playground Equipment, and made recommendations to the Legislator in the
State of California (CDHS, 1987). As a result of the findings and recommendations of that
report, a new law was signed into effect in September 1987 (Div. 20 of the California Health and
Safety Code, §25930.10.7) (Spease, 2002). The law stated that:
•
•
•
State funds could not be used to purchase wooden playground or recreational
equipment that may have been treated with arsenic (unless treated in accordance
with AWPA standard C-17), pentachlorophenol or creosote;
State funds may not be used for maintenance of the wooden playground or
recreational equipment in question; and
People installing any such structures must seal the structures with a non-toxic,
non-slip sealer at the time of installation, and reseal the structure every two years.
Maine legislators approved the Nation’s first ban on the sale of wood treated with arsenic
on June 4, 2003. The bill states “that beginning April 1, 2004, Maine lumber dealers can no
longer sell arsenic-treated lumber for use in residential construction” (Edgecomb, 2003).
Additionally, retailers are prohibited from purchasing arsenic-treated wood for most residential
uses (mid-September 2003). The Maine Department of Environmental Protection (MDEP) must
complete a market evaluation of remaining uses. The Maine Bureau of Health must develop
informational brochures to educate consumers by January 1, 2004, on what homeowners should
know about hazards, and methods for reducing exposures with sealants. By January 1, 2005, the
MDEP must develop plans to restrict the disposal of arsenic-treated wood (Our Stolen Future,
2003).
In New York, Section 37-0109 of the New York State Environmental Conservation Law
makes it illegal for schools and public playgrounds to have playground equipment constructed
from pressure treated lumber that contains CCA. The law requires that existing playground
2-8
equipment be sealed to stop CCA from leaching or escaping from the wood, and to cover the
ground to protect children from arsenic that may have leached to the soil. The Department of
Environmental Conservation (DEC) is to publish information on the dangers and hazards to public
health and the environment from the use of CCA-treated lumber. The DEC is to compile and
publish a list of less toxic materials that may be used on playgrounds as an alternative to CCAtreated lumber. The DEC will also compile and publish information on non-toxic methods and
materials that are available to seal playground structures with CCA wood and to cover the ground
(Healthy Schools Network, 2003).
Other state agencies such as the Connecticut Department of Public Health, the
Massachusetts Department of Public Health, the Florida Department of Environmental Protection,
and the Minnesota Department of Health have been actively investigating issues related to
pressure-treated playground equipment. They have provided public health information on arsenic
in pressure-treated wood, as well as safety recommendations for homeowners (see websites listed
in Table 2-2). These recommendations include:
•
•
•
•
•
•
•
•
•
•
Sealing CCA-treated structures (decks and playsets) every two years with
oil-based stain;
Preventing exposure to pressure-treated wood and dust;
Washing hands after playing on wooden playground equipment;
Inspecting structures for decay;
Suggesting alternatives to CCA-treated pressure treated wood;
Not placing food, drink or paper products on pressure treated wood;
Never burning treated wood;
Limiting use of under deck areas where arsenic may have accumulated in the soil;
Not using treated wood on indoor surfaces; and
Not using CCA-treated wood for wood chips or mulch.
Table 2-2 presents a summary of state regulatory activities and actions related to CCA.
2-9
Table 2-2. State Regulatory Actions and Activities Related to CCA
State
Summary of Actions and Activities
Website Source
California
In 1987, the California Department of Health Services
(CDHS), Health and Welfare Agency conducted a research
study entitled, Evaluation of Hazards Posed by the Use of
Wood Preservatives on Playground Equipment and made
recommendations to the Legislator in the State of California
(CDHS, 1987). As a result of the findings and
recommendations of that report, a new law was signed into
effect in September 1987 (Div. 20 of the California Health
and Safety Code, §25930.10.7). Legislation required that
publically-maintained wooden playground or recreation
equipment be treated with a certain formulation of CCA.
This legislation also required that existing
publically-maintained wooden playground/recreation
structures made with arsenic-treated wood be sealed with a
non-toxic and non-slippery sealant every two years. CDHS
provides public health information on arsenic in pressuretreated wood, safety recommendations for homeowners, as
well as additional information on their website.
http://www.dhs.cawnet.gov
Connecticut
The Connecticut Department of Public Health provides
public health information on arsenic in pressure treated
wood, safety recommendations for homeowners, as well as
additional information on their website.
http://www.state.ct.us/dph
Florida
Proposed legislation would prohibit the public use of CCAtreated wood in playground structures and associated ground
covers that are constructed or contracted for by October 1,
2003. It would require that existing publically-maintained
wooden playground/recreation structures made with arsenic
treated wood be sealed with a non-toxic and non-slippery
sealant every two years. Florida Department of
Environmental Protection provides public health
information on arsenic in pressure-treated wood, safety
recommendations for homeowners, as well as additional
information on their website.
http://www.dep.state.fl.us
Maine
Legislature approved a bill that states “ beginning April 1,
2004, Maine lumber dealers can no longer sell arsenictreated lumber for use in residential construction.”
Additionally retailers are prohibited from purchasing
arsenic- treated wood for most residential uses
(mid-September 2003). The Maine Department of
Environmental Protection (MDEP) must complete a market
evaluation of remaining uses. The Maine Bureau of Health
must develop informational brochures by January 1, 2004,
on what homeowners should do know about hazards, and
methods for reducing exposures with sealant. By January 1,
2005, the MDEP must develop plans to restrict the disposal
of arsenic treated wood.
http://www.state.me.us/dhs/boh
http://www.state.me.us/dep
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Table 2-2. State Regulatory Actions and Activities Related to CCA (Continued)
State
Summary of Actions and Activities
Website Source
Massachusetts
The Massachusetts Department of Public Health provides
public health information on arsenic in pressure-treated
wood and safety recommendations for homeowners on their
website.
http//:www.state.ma.us/dph
Minnesota
In Minnesota, a bill has been introduced that would ban the
use and sale of CCA in the state. A second Minnesota bill
would require that schools that use CCA-treated products
seal the wood every two years (Environmental Health
Perspectives, 2001). Minnesota Department of Health
provides public health information on arsenic in pressure
treated wood, safety recommendations for homeowners, as
well as additional information on their website.
http//:www.health.state.mn.us
New York
In New York, Section 37-0109 of the New York State
Environmental Conservation Law makes it illegal for
schools and public playgrounds to construct playground
equipment from pressure-treated lumber that contains CCA.
The law requires that playgrounds be sealed to stop CCA
from leaching or escaping from the wood, and to cover the
ground to protect children from arsenic that may have
leached to the soil. The New York Department of
Environmental Conservation provides public health
information on arsenic in pressure-treated wood, safety
recommendations for homeowners, as well as additional
information on their website.
http//:www.dec.ny.us
2.2.3 Use Profile of CCA
CCA preservatives protect wood from deterioration from a variety of insects, fungi, and
rot organisms. There are currently 26 CCA-containing wood preservative products registered
with the EPA. CCA is used for pressure-treated lumber intended for outdoor use in constructing
a variety of residential landscape and building structures, as well as home, school, and community
playground equipment. However, it should be noted that EPA granted the voluntary cancellation
and use termination requests of CCA-treated wood. The labels for the three CCA-containing
preservatives that contained the non-pressure treatment uses were effectively canceled via a 6(f)
notice on May 16, 2003. A final cancellation order was issued on May 28, 2003 for Osmose
Special K-33 Preservative (EPA Registration 3008-21), Hollow Heart Concentrate (EPA
Registration 75341-1) and Osmoplastic SD Wood Preserving Compound (EPA Registration
75341-7). The cancellation of these three products resulted in pressure treatment being the only
allowable use for CCA-containing preservatives. CCA is used for pressure-treated lumber
intended for outdoor use in constructing a variety of residential landscape and building structures,
as well as home, school, and community playground equipment. However, it should be noted,
EPA granted the voluntary cancellation and use termination requests affecting virtually all
residential uses of CCA-treated wood. CCA-treated wood, predominantly of Southern yellow
2-11
pine, represents the majority of pressure-treated dimensional lumber marketed to the general
consumer via lumberyards/hardware stores and other retailers. In some cases, CCA-treated
lumber is recycled into wood chips which are stained, then sold to consumers as landscape mulch.
Major commercial installations include utility poles, highway railings, roadway posts/barriers,
bridges, bulkheads, and pilings. Industry cites advantages of CCA-treated wood over other
pressure-treated wood, including superior durability, low-odor, and dry “non-oily” surfaces which
can be painted or sealed.
There are three formulations of CCA, each containing varying ratios of arsenic pentoxide,
chromic acid, and cupric oxide. CCA treatment solutions are typically classified by the American
Wood-Preservers’Association (AWPA) as either type A, B, or C, with CCA type C (CCA-C)
being the formulation most commonly used for pressure treating dimensional lumber for
residential applications. AWPA’s P5 Preservative Standard requires CCA-C composition to be
34.0% arsenic pentoxide (As2O5), 47.5% chromic acid (CrO3), and 18.5% cupric oxide (CuO)
(AWPA, 1998).
After pressure treatment and fixation, arsenic and chromium can be retained in the wood
from 0.25 to 2.50 pounds per cubic foot (pcf), based on the retention of CCA-C in wood
following AWPA treatment standards. Typical retention levels achieved depend on the intended
applications of the treated lumber. Lower retention values are required for plywood, lumber, and
timbers used for above-ground applications (0.25 pcf ), and for ground or freshwater contact uses
(0.40 pcf). Higher retention levels are required for load bearing wood components, such as
pilings, structural poles, and columns (0.60 - 0.80 pcf). The highest levels are required for wood
foundations and saltwater applications (up to 2.50 pcf).
Nationwide, approximately 70% of single family homes have existing pressure-treated
decks and porches, and approximately 14% of public playground equipment is made with treated
wood. Based on current data from the American Chemistry Council (ACC), approximately 34%
of CCA was used for decks and less than 1% was used in playground equipment (Zartarian et al.,
2003; CPSC, 2003b). The potential for exposure to pesticide residues remaining on the surfaces
of the existing aged treated wood structures as well as to the residues leached into the
surrounding soil, may pose child health hazard concerns.
2.2.4 Overview of CCA Chemistry
CCA contains chromium (Cr), copper (Cu), and arsenic (As), each of which contributes to
the wood-preservative properties of the compound. Copper acts as a fungicide in the CCA
formulation and the arsenic protects against insect damage. Chromium, in the form of chromic
acid, acts as a fixative (binding agent), whereby the Cr, Cu, and As metal ions present in the wood
are fixed to the wood fibers. Most of the information presented in this overview is from U.S.
EPA (2001b).
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Metals go through various changes in environmental compartments such as soil, water,
plants, and animals. The speciation of metals depends on sorption, desorption, redox reactions in
soil and water, precipitation reactions, complexation reactions, etc. (Lebow, 1996). The different
species of arsenic and chromium vary in their ability to be absorbed into the body and metabolized
within the body, and differ in their toxicological profiles. Therefore, it is important to consider the
species of arsenic or chromium present in soils surrounding CCA-treated wood and on the surface
of the treated wood itself when assessing the exposure to these chemicals.
2.2.4.1
Speciation
The FIFRA SAP (U.S. EPA, 2001c) noted that there is no reliable evidence on either the
presence or absence of Cr(VI) in dislogeable residues on treated wood surfaces. However, since
that meeting, more studies have indicated that Cr(III) is the primary component on treated wood
surfaces. The FIFRA SAP also noted that some measurable Cr(VI) probably exists in certain
soils, but it is unlikely to be 100 percent of the total chromium present. One approach
recommended by FIFRA SAP in evaluating the hazards of chromium in the soil would be to use
an estimate of 5 to 10 percent (or more conservatively 25 to 50 percent) Cr(VI).
More recent studies indicated that Cr(III) is the primary component in CCA pressuretreated wood surfaces of existing decks and playground structures (RTI International, 2003 (cited
as ACC, 2003b in SHEDS-Wood Report); Cooper, 2003; Nico et al., 2003) and in the air of
treatment plants (ACC, 2002). In fact, RTI International (2003) found that Cr(VI) was not
detected in 142 of 145 wood surface dislogeable residue samples taken; Cr(VI) was not detected
in any of the samples from existing aged decks, and only trace amounts were detected in the
newly treated woods in the remaining samples. The registrants of CCA conducted a CCA
treatment plant worker exposure study in 1999 (ACC, 2002). This study also indicated that the
Cr(VI) in the air was undetectable (based on the sensitivity of the limit of detection of Cr(VI)
used in that study). Nico et al. (2003) found that chromium and arsenic in CCA-treated wood
were consistent between samples of fresh treated wood and aged wood, and between treated
wood and dislogeable residue. The Nico et al. (2003) report indicated that a “chemical complex”
type of matrix was formed between As-Cr-Wood. However, the Nico et al. (2003) report did not
quantify the matrix type of CCA-treated wood and the free metal forms of arsenic and chromium.
2.2.4.2
Fixation
After undergoing pressure treatment with CCA wood preservative, the chromium, copper
and arsenic penetrate into the wood and become bound or fixated in the wood. The term,
fixation, refers to the series of chemical reactions that take place after the wood has been pressure
treated with CCA. These reactions render the CCA less likely to leach from the wood during
service. The use of metal oxides in CCA formulations has been shown to aid in the fixation
process. Fixation precedes the actual action of CCA to act as a wood preservative. The CCA
penetration/fixation process preserves and protects the wood from pest attack. The absorption
and fixation of CCA apparently occur in the cellulosic and lignin components of the wood (Kartal
2-13
and Lebow, 2000). Since lignin is thought to be a primary binding site for chromium to form
chromium-lignin complexes, the use of woods with an increased lignin content may result in
improved treatment. Softwood species, which have a high lignin content often perform better than
hardwoods in terms of preservative treatment. Studies have shown that all of the three metals are
fixed into the wood structure.
The initial reaction of fixation is the absorption of the CCA preservative into the cellulosic
and lignin components of the wood. A second reaction occurs which converts Cr(VI) to Cr(III).
This second reaction continues for a period of several hours to a few days. The reduction of
Cr(VI) to Cr(III) is important in the formation of insoluble complexes in CCA-treated wood.
Additionally, Cr(III) is less toxic than Cr(VI). The third reaction is the conversion of copper
arsenate in the wood to basic copper arsenate with an arsenic valence state of +5. The complete
fixation reaction may even take several months. Studies with treated pine have indicated that the
copper and arsenic components of the CCA metals are “fixed” more rapidly than chromium.
Some researchers have concluded that the fixation process is complete when the presence of
Cr(VI) is no longer detected in the leachate or compensate of the treated wood. Cooper (2003)
conducted research on CCA fixation using existing data and noted that virtually all of the
chromium injected into the wood during the treating process is eventually reduced to low toxicity
Cr(III) and there is no evidence that Cr(VI) is produced as a result of the oxidation of Cr(III) in
the wood. The completion of the fixation process can be from a few days to a several months,
depending on the ambient temperature of treatment plants.
2.2.4.3
Leaching
The fixation process binds much of the chromium, copper, and arsenic into the wood
fibers; however, some of the metals will not be “fixed” and will remain “free” on the surface of the
treated wood. These will be susceptible to dislodging through washing off or by physical contact
with other objects, including humans who have physical contact with the wood. The fixated
metals can also slowly be leached from the treated wood by water.
Playground equipment constructed with treated wood can be in the form of many different
types of items including swing sets, climbing bars, etc. The chromium, copper, and arsenic in/on
the treated wood can be leached from the wood so that the metals fall vertically onto the soil
under the equipment and leach laterally into the soil from the vertical pieces of treated wood that
have contact with the playground soil. Metals also leach from ground-contact horizontal pieces of
CCA-treated wood fabricated into playsets and related structures. Playground equipment may
also have mulch placed under the equipment, and the mulch will receive leachate from the treated
equipment pieces. Children playing on such equipment can be exposed to the CCA leachates
either through contact with the CCA-treated wood or through contact with soil or mulch either
under the equipment or immediately adjacent to the equipment.
2-14
A large amount of data are available regarding the leaching of chromium, copper, and
arsenic from treated wood (Lebow, 1996). Much of the data are from studies that are not directly
applicable to leaching from playground equipment. Some of the available data that are most
applicable to playground equipment and decks constructed of CCA-treated wood are summarized
below.
Leaching of chromium, copper, and arsenic from treated wood in an aqueous medium,
which is most likely to simulate the playground use (where rainfall occurs), appears to be most
rapid from freshly treated wood and is in the order of Cu > As > Cr. The release rate is also
higher under acidic conditions; this would mean that leaching would be faster in the areas of the
United States that have acid rain, such as the northeastern states. One study has shown that the
leaching process from treated wood is aided by slow or drizzling rain rather than heavy showers.
Leaching rates are generally lowest in wood that has been kiln-dried at high temperatures.
Most of the leaching from treated wood appears to take place in the first few days after
treatment, but continues slowly over time (Lebow, 1996). Leaching rates depend on the size of
the wood, type of wood, and on the fixation process. CCA leaches from hardwood more than soft
wood. Pressure treated red pine leaches more than lodgepole pine and Douglas fir. A scheme has
been proposed in the literature for the long-term leaching mechanism of CCA from wood:
reversible disassociation of ion-exchanged metals and their redistribution to the wood surface and
their loss; and physical or biological decay of the wood.
No leaching information was found to address the question of whether CCA metals leach
from treated wood as copper or copper arsenate, or as complexes with inorganic or organic
ligands, or as derivatives of wood-metal moieties or as water soluble extracts. Water mobility for
the metal ions from CCA depend on many factors which give rise to a number of pathways. The
metals can diffuse through the soils as complexes, simple salts or free ions, or can percolate
through soils as insoluble substances.
Little data were found to estimate the level of CCA residues in soil or mulch under
playground equipment constructed of treated wood. A Canadian study evaluated wooden play
structures consisting mostly of CCA-treated lumber of various dimensions constructed in a range
of designs (Riedel et al., 1991). The structural elements were comprised of beams and planks
fastened together. Poles were cut and used to form rungs, ramps and ladders. Treated wood
pieces were used to construct tower-like structures and to connect to swings, slides, ladders or
horizontal monkey bars. Some structures incorporated hut-like shelters. Treated wood pieces
were placed in vertical, horizontal and angled positions. Some structures were coated with an oilbased stain which had worn off in some areas. The structures were up to ten years old. The
ground under the structures and surrounding the structures usually consisted of a layer of sand at
least 25 centimeters deep which is replaced or replenished from time to time. The sand is carried
onto the structures and contributes to the abrasion and wear on the treated wood pieces.
2-15
Sand and soil samples were taken from under each of the treated playground structures
and a control soil sample was taken at a distance of ten meters (33 feet) from the treated
playground structure. The sand samples were taken at similar locations under each structure; at
the bottom of a slide, next to a support post, at the bottom of a support post holding the main
structure, and underneath a wooden platform or underneath a structure approximately one meter
from the wooden post. The samples were all taken in late fall and on a cloudy day. The soil
samples were stored in plastic bags and taken to the laboratory for analyses. The samples were
oven dried and analyzed using inductively coupled plasma mass spectrophotometry for total nitric
acid soluble arsenic (not speciated). Neither chromium nor copper were analyzed in the sand and
soil samples. The background levels of arsenic present in the control sand samples were generally
less than 0.3 parts per million (ppm). The authors of the paper reported that the average arsenic
residue level from samples taken from below the treated structures was 3.0 ppm with a range of
0.032 - 9.6 ppm. However, sand samples taken from other areas around the playground
structures showed arsenic residues ranging from 0.13 ppm to 113.5 ppm under a structure next to
a post. It should be noted that arsenic residues in sand sampled next to a treated post were less
than 10 ppm except in the one playground with the high 113 ppm value. That study showed
significantly higher sand residues than the other playground studies. There is no explanation for
this difference, but could be due to reasons such as samples being taken near newly treated and
replaced wood posts. Additionally, sand had been placed under the structures and leaching from
wood posts into the sand may be more rapid and spread further from the post than would be the
case for arsenic leaching into a clay soil. It could also be argued that if wood mulch rather than
sand had been placed under the playground structures that, because of the surface area to weight
relationship for this organic material, any arsenic residues leaching from treated wood could result
in even higher arsenic residues in the mulch under the playground equipment.
The playground where arsenic residues were highest was ten years old and constructed of
wood that had been stained, but on which the stain had been worn off. There did not appear to be
a correlation between residue levels in the sand under and around the playground structures and
whether the equipment had been stained or painted, or was left unsealed.
There are also data available showing soil residue levels that occur under wooden decks
that have been constructed from CCA-treated wood. Children can play in the soil under and
around a treated deck. While the deck data may exaggerate residue levels in soil compared to
what would be expected under playground equipment, the data show that the level of CCA metals
in soil under treated wood structures was greater than the background level of the metals in soil
from the study location and show residue levels in soil where children could play.
In one study conducted by Stilwell and Gorny (1997), soil from under seven decks
constructed from CCA-treated wood were analyzed. Chromium levels ranged as high as 154 ppm
under the treated decks and averaged 43 ppm, whereas, the control soils had an average of 20
ppm of chromium. Arsenic levels ranged as high as 350 ppm under the treated decks and averaged
76 ppm, whereas, the control soils had an average of 3.7 ppm of arsenic. No data are available for
mulch under the treated deck, but residues in mulch may even be higher because of the surface
2-16
area weight relationship of mulch. The same study showed that those decks that had been coated
tended to show a lesser degree of leaching of CCA metals. However, the degree of leaching from
a deck that had been coated or sealed would most likely be dependent on the coating product
used and on the age of the coating. The same study also showed that the age of the deck was a
factor in the leachate residues found under the treated deck, with the older deck showing higher
soil residues under the treated deck. This study does not reflect the soil CCA residue levels that
could occur under treated playground equipment, but the generalization can be made that CCA
residues in soil under treated playground equipment will be higher than soil background levels of
the CCA metals in the surrounding area. The residue data from this study do not speciate the
metals but determine total copper, chromium, and arsenic.
Lateral and vertical migration of CCA metal residues can also occur from vertical pieces
of the playground equipment that have contact with the soil. In a study conducted by DeGroot et
al. (1979), treated southern pine wooden stakes were placed in sandy soil, and the lateral and
vertical migration of CCA metal residues were measured after 30 years. Both arsenic and
chromium residues leached into the top six inches of a soil core, arsenic as high as 108 ppm and
chromium as high as 25 ppm. Some increase in arsenic levels, but not chromium levels, was seen
in the six- to twelve-inch core. In the twelve- to eighteen-inch core, there did not appear to be any
increase in the arsenic and chromium level. In soils which have a high clay or organic content,
metal leaching would be expected to be lower because of the metal binding to the soil particles.
Lateral movement of residues in the soil surrounding the stakes appeared to be limited to the
zero- to three-inch area surrounding the treated stakes. Based on the findings in this and other
studies, CCA metal residues are not likely to leach from vertically-placed wood structures placed
in contact with the soil to depths greater than twelve inches or to lateral distances from these
treated wood pieces of greater than three inches.
In another study conducted in Florida with CCA-treated decks (Townsend et al., 2001),
nine decks were studied (one deck could not be confirmed as treated with CCA). The decks were
located in Gainesville, Miami, and Tallahassee and sampling was conducted in 1999. The decks
varied in age from two to nineteen years old. A grid was set up under each deck before sampling
where soil samples were collected. Surface samples, from the top inch of soil, and soil core
samples, of approximately seven inches in depth, were taken. Soil control samples were also taken
at locations away from the grid. The soil samples were digested and analyzed for total arsenic,
copper, and chromium. Analyses were performed using an atomic absorption spectrophotometer.
This method determines the total metal residue level and does not speciate the metals.
Arsenic residues were found in the soil beneath all of the CCA-treated decks. The average
surface arsenic level was 39 ppm and the maximum level under one deck was 217 ppm. The
maximum arsenic residue found under any of the other decks was 88 ppm. The maximum arsenic
residues present in soil core samples were in the top two inches, but were present at levels of
approximately 2-20 ppm over the depth range of two to eight inches. Control arsenic values
average 1.5 ppm.
2-17
The average surface copper residues found in the soil beneath all of the CCA-treated
decks was 40 ppm and the maximum level under one deck was 216 ppm (soil from the same deck
reported high arsenic levels). The maximum copper residue found in soil under any of the other
decks was 156 ppm. The maximum residues present in soil core samples were generally higher in
the top few inches of soil, and were higher than those levels in control samples.
The average surface chromium residues found in the soil beneath all of the treated decks
was 34 ppm and the maximum level under one deck was 198 ppm (soil from the same deck that
reported high arsenic levels). The maximum chromium residue found in soil under any of the other
decks was 114 ppm. The average control level was 9.8 ppm. Average chromium levels of up to
11.7 ppm were reported at depths of 4.5 inches.
The soils under the CCA-treated decks are described as ranging from beach sand to being
dark in color with a sponge-like consistency and with a high percentage of volatiles given off
during analysis. This latter observation seems to indicate a soil with high organic content. The site
with the highest arsenic level was characterized as having relatively high volatile solids, and this
correlation can be found in five of the nine deck sites. The lowest arsenic residues were found at
sites with low volatile solids content (Townsend et al., 2001). This study indicates that CCAtreated decks increase arsenic, copper, and chromium levels in soil beneath treated decks.
Based on the available information from both CCA-treated playground equipment and
decks, it appears that the primary source of soil exposure to children from playing on playground
equipment constructed of CCA-treated wood or playing under treated decks would occur from
the leaching of CCA metal residues from horizontal pieces of treated wood in the playground
equipment and deck wood onto the soil. Maximum residue levels would likely be less than 200
ppm arsenic, copper, and chromium, and, on the average, would be less than 50 ppm for each of
the metals. Maximum residues of arsenic would likely occur in sandy soil under treated wood.
However, if an organic material such as wood mulch with a high surface to weight relationship
were placed under CCA-treated playground equipment, residues of the metals could be absorbed
and retained in the material with slow leaching from the mulch. All three of the leaching studies
described above are suitable to show that residues of copper, chromium, and arsenic leach from
treated wood onto the soil under playground equipment and decks constructed of treated wood.
Additional studies would be desirable, which reflect the use of CCA-treated wood in playground
equipment, specifically, studies designed to sample soils beneath/adjacent to CCA-treated
playground structures from different (representative) geographic regions of the United States.
2.2.4.4
Environmental Fate
Many studies in the recent literature (Lebow, 1996; Stilwell and Gorny, 1997; Stilwell,
1998; Townsend et al., 2001; Osmose, 2000) report on leaching into soils. These studies have
shown that none of the three metals migrate large distances (twelve inches vertically and three
inches laterally) from the treated wood structure. Some studies have shown that the
contamination level is elevated in the soil compared to the natural background levels of these
2-18
metals. Such studies indicate that metals can be persistent in the soils, particularly on the soil
surfaces, and can result in environmental exposure. The metals show various speciation
characteristics in soils, depending on the types of soil.
The metals migrating into water bodies can result in aqueous contamination. Metals also
show a tendency to speciate in water, and various species will be present in water depending on
the pH of water as well as the salinity. If water is highly acidic, the leaching rates and amounts of
leachates increase. Generally, in soil and water, the amounts of metals released are in the order of
Cu > As > Cr. In some recent cases it has been shown that the order of release rates are: As > Cu
> Cr. In all cases, the amounts of chromium released is least of the three metals.
Numerous studies on bioaccumulation in various aquatic organisms have also been carried
out over a period of time. A number of these aquatic species have shown a degree of
bioaccumulation, and toxic effects have been observed. The studies were conducted under varying
conditions and very few studies reported depuration rates.
An overall robust fate assessment cannot be made at this time, as the studies were
conducted under different laboratory or field conditions, which were not standardized. Hence,
while one can determine the exposure and hazards of these metals on humans, plants, and aquatic
organisms, a complete fate assessment is not possible.
2.2.5 CCA Use and Potential Exposures to Components of CCA
The Agency is aware of potential exposure concerns to arsenic and chromium components
of CCA-treated wood in decks and playground structures, and contaminated soils commonly
found in these settings. During the pressure treatment of wood, CCA undergoes a fixation process
where it initially is absorbed into the cellulosic and lignin structures of the wood. Chromium in
the form of Cr(VI) attaches itself to the ‘carboxylic groups’of the cellulosic structure and
converts into Cr(III). Copper arsenate converts into basic copper arsenate. In pressure-treated
wood, arsenic leaches to the surface of the wood mostly as As(V), but there may be some As(III).
Chromium leaches mostly as Cr(III); however, trace amounts of Cr(VI) may also be present.
Copper is present as Cu(II) (U.S. EPA, 2001b).
Of the components in CCA, copper does not pose significant toxicity concerns compared
to arsenic and chromium. Copper is an essential nutrient that functions as a component of several
enzymes in humans, and the toxicity of copper in humans involves consumption of water
contaminated with high levels of copper (U.S. EPA, 2001b). Because of the relatively low toxicity
of copper, the Agency did not conduct an exposure/risk assessment for copper. For chromium,
hazard data clearly show that Cr(VI) demonstrates more significant toxicity than Cr(III)
(Zartarian et al., 2003). Thus, the Agency felt that it would not be credible to apply Cr(VI)
toxicity endpoints to Cr(total) residue results to assess incidental ingestion and dermal exposures
in children. Since the Agency has not identified any endpoints of concern for Cr(III), the shortterm intermediate-term and lifetime risks to Cr(III) are not presented.
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2.2.6 Probabilistic Risk Assessment versus Deterministic Risk Assessment
A probabilistic assessment (i.e., using SHEDS-Wood) was conducted to evaluate
exposure to CCA (Zartarian et al., 2003). A probabilistic exposure assessment uses probability
distributions for one or more variables in a exposure equation in order to quantitatively
characterize variability and/or uncertainty. A Monte Carlo Analysis (MCA) is perhaps the most
widely used probabilistic method. MCA uses computer simulations to combine multiple
probability distributions in exposure or risk equations. In contrast, a deterministic assessment
uses point estimates for each of the variables in the exposure algorithm. The result is a single
estimate of exposure dose. The output of a probabilistic assessment is a probability distribution of
exposures that reflects the combination of the input probability distributions. If the input
distributions represent variability, then the output distribution can provide information on
variability in the population of concern. The input/output uncertainties of this assessment are
discussed in Zartarian et al. (2003) If the input distributions reflect uncertainty, then the output
distribution can provide information about uncertainty in the estimate. Information from SHEDSWood can be used in combination with toxicity data to form a probabilistic risk assessment
(PRA). The PRA can be used to make statements about the likelihood of exceeding a risk level of
concern, given the estimated variability in elements of the risk equation. Since the results of point
estimate methods generally do not lend themselves to this level of risk characterization (e.g.,
quantitative uncertainty assessment), the PRA can provide unique and important supplemental
information that can be used in making risk management decisions.
Table 2-3 summarizes the key differences between deterministic and probabilistic risk
assessment methods. From this table it is easy to understand why a probabilistic risk assessment
was conducted in assessing the risks from CCA-treated deck and playground equipment.
Table 2-3. Comparison of Deterministic and Probabilistic Risk Assessments
Deterministic Risk Assessment
Probabilistic Risk Assessment
Data Input
Pesticide concentrations and potential
exposure factors are expressed as single
point estimates.
Takes into account all available
information and considers the probability
of an occurrence.
Risk Estimates
Expressed as a single point value. The
variability and uncertainty of the value is
not reflected.
Expressed as a distribution of values, with
a probability assigned to each value.
Distribution reflects variability and can
provide risk manager with information
helpful to determine what particular range
of the risk estimate distribution most
closely represents real life scenarios.
Resources
Less time and not resource intensive,
calculation is relatively simple, but
provides little information about the
proportion of the population receiving the
estimated exposure.
May require more time and resources for
seeking credible software to use for
specific site.
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Table 2-3. Comparison of Deterministic and Probabilistic Risk Assessments (Continued)
Deterministic Risk Assessment
Probabilistic Risk Assessment
Methods
Useful for screening method - easily
described.
More complicated for risk manager who
may need time to understand the
methodology.
Risk
Communication
Single point risk estimates are often
viewed as “the answer”; public perception
may be misled.
Communication of uncertainty in the risk
assessment can help to build trust among
stakeholders.
Uncertainties
Qualitative; importance of variability is
sometimes lost.
Provide quantitative information and a
more comprehensive characterization of
variability associated with in input
parameters.
Regulatory Concern
Does not quantify the probability that the
risk estimate exceeds a regulatory level of
concern.
Can identify the data gaps for further
evaluation/data collection and can use
wider variety of site-specific information.
Data Analysis
May not utilize all available data for
characterizing variability and uncertainty
in risk estimates; provides fewer
incentives for collecting better and
credible information
Complete use of available data when
defining inputs to the risk equation; and
can provide more comprehensive
characterization of variability in risk
estimates.
Sensitivity Analysis
Only limited to dominant exposure
pathways and chemical of concern
Can identify the exposure variables,
probability models, and model parameters
that influence the estimates of risk.
EPA recognizes that there are many parameters that affect the level of potential exposure
and that each of these parameters may vary. Probabilistic (e.g., Monte Carlo) techniques are
capable of using multiple data sets which reflect the variability of parameters to produce estimates
of the distribution of potential exposures. OPP has identified a number of data sets that contain
information on the variability of parameters affecting the levels of exposure to CCA residues
experienced by children as a result of their playground activities.
Children playing on decks and playgrounds that are built out of CCA pressure treated
wood can be exposed to arsenic and chromium residues on wood surfaces and soils via oral and
dermal routes. OPP has considered four proposed exposure scenarios individually in their
previous assessment; however, to more comprehensively assess risks to children from exposure to
arsenic through deck and playground contact with wood and soil, all four scenarios must be
considered concurrently. PRAs present the most flexible tool to examine combined activities
concurrently. The advantages of conducting a probabilistic risk assessment are as follows:
2-21
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PRAs more comprehensively address the distributions and variabilities of multiple
sets of data in both inputs and outputs;
PRAs offer more in depth analysis of uncertainty for both inputs and outputs;
PRAs present the most flexible tool to examine combined activities concurrently;
For residential exposure, children may be exposed to residues from playsets, decks,
and soil concurrently;
PRAs allow for more subsets of data (e.g., warm or cold environments, hand
washing, bathing, etc.) and allow the user to separate the data and consider
different exposure considerations;
PRAs characterize more of the statistical uncertainties and special sensitivities for
certain population groups (e.g., pica children);
PRAs may show the actual shape of the composite distribution. For example, the
actual distributions of the data may be lognormal instead of normal distribution;
PRAs account for covariance between variables. The variance of the product could
be inflated if there is a positive correlation between the variables;
PRAs show the influence of a particular data set on the exposure, and graphically
depict the data;
PRAs show the distributional quartiles;
PRAs use sophisticated software that can reproduce the calculation quickly and
accurately;
PRAs allow for a comprehensive sensitivity analysis that can identify the exposure
variables, probability models, and model parameters that influence risk; and
PRAs more accurately quantify the upper bound high-end percentile of total risk to
more accurately help the risk managers make decisions based on the data.
2.2.7 EPA and OPP Regulatory Approach to PRA
Agency policy is that risk assessments should be conducted in a tiered approach,
proceeding from simple to more complex analyses as the risk management situation requires
(Agency Policy Document, 5/15/97)(U.S. EPA, 1998a). More complex analyses require greater
resources, and probabilistic assessments can represent high levels of complexity. In a
deterministic assessment, exposure is expressed as a single value, which could represent an upperbound scenario or a central tendency. If a deterministic analysis, based on conservative
assumptions, leads to risk estimates that are below levels of concern, then there is no need to
refine risk assessments with more complex techniques (U.S. EPA, 1998a). However, if a
conservative deterministic assessment leads to estimates above the level of concern, more
sophisticated risk assessments may be warranted.
Probabilistic techniques offer a higher level of sophistication. In contrast to deterministic
techniques, probabilistic risk assessments more fully consider ranges of values regarding potential
exposure, and then weights possible values by their probability of occurrence. Individual input
values used to generate a point estimate are replaced by a distribution reflecting a range of
potential values; a computer simulation then repeatedly selects individual values from each
2-22
distribution to generate a range and frequency of potential exposures. In accordance with Agency
policy at the current time, such techniques will not be considered for dose-response evaluations of
toxicological data (U.S. EPA,1998a), but are limited to exposure assessments.
2-23
3.0 EXPOSURE ASSESSMENT
Note: This chapter only provides a summary of the SHEDS-Wood exposure doses used for
the risk assessment. For the detailed probabilistic SHEDS-Wood exposure
assessment please refer to Zartarian et al. (2003), A Probabilistic Exposure
Assessment for Children Who Contact CCA-Treated Playsets and Decks, Draft Final
Report, September 25, 2003.
SHEDS-Wood, a probabilistic exposure model developed by ORD, was used to develop
the exposure assessment for CCA. The exposure assumptions, pathways, exposure routes,
algorithms, and methodologies for this model are explained in detail in a separate exposure report,
Zartarian et al. (2003), prepared by ORD and OPP entitled, A Probabilistic Exposure Assessment
for Children Who Contact CCA-Treated Playsets and Decks. The SHEDS-Wood document
provides exposure doses as ADD and LADDs; it does not provide a risk analysis. A general
description of the exposure assessment approach for this model and a brief description of how the
probabilistic exposure assessment data were used in the risk analysis are described in the narrative
below.
The SHEDS-Wood probabilistic exposure model evaluated exposure of children for two
chemicals (arsenic and chromium) in two environmental media (soil and surface residues).
Arsenic exposures were generated as both noncancer exposure doses (ADDs) and cancer
exposure doses (LADDs). For chromium, only noncancer exposure doses (ADDs) were
necessary (refer to Chapter 4 for a discussion of chromium carcinogenicity). Thus, the Zartarian
et al. (2003) probabilistic exposure assessment provided only chromium total ADDs for both
residues and soil (i.e., LADDs were not generated). However for chromium, OPP made a
decision to assess noncancer risks using soil ingestion ADDs only, because of the lack of
detectable surface residues for Cr(VI) (see Chapter 2) and because of no specific dermal toxicity
end-point exists for Cr(VI) (see Chapter 4). In addition, OPP and the FIFRA SAP were
concerned that combining total chromium doses with Cr(VI) toxicity endpoints would
overestimate chromium risks. Because of this concern, ADDs for soil ingestion were developed
specifically for Cr(VI) in this assessment. The Cr(VI) soil ingestion ADDs were derived based on
the SAP Panel recommendations for chromium speciation (see Chapter 2). In summary, the total
chromium soil ingestion ADDs originally provided in the SHEDS-Wood data files were adjusted
by multiplying the data by 0.10 (10%) to account for the portion of total chromium that is
assumed to be present as Cr(VI) because of speciation.
Because there are two routes of exposure (dermal and oral) and two environmental media
(soil and surface residues), SHEDS-Wood evaluates exposure based on four scenarios. These
scenarios are: dermal contact with CCA-treated wood, dermal contact from CCA-contaminated
soil near treated wood structures, mouthing hands after touching CCA-treated wood, and
ingesting CCA-contaminated soil. SHEDS-Wood was used to evaluate three exposure durations
3-1
short-term, intermediate-term, and average lifetime exposures (only for arsenic). The potentially
exposed populations for this assessment are (1) children in the United States who contact CCAtreated wood (from decks and/or playsets) and/or (2) children in the United States who contact
CCA-containing soil from public playsets (e.g., at a playground, a school, a daycare center). A
subset of these children was also assumed to contact CCA-treated wood residues and/or CCAcontaining soil from residential playsets (i.e., at the child's own home or at another home) and/or
residential decks (i.e., at the child's own home or another home). This population was selected
because of the particular focus by CPSC and other groups on playground playsets in conjunction
with EPA's focus on estimating the risk to children from various primary sources of CCA-treated
wood that children may contact (Zartarian et al., 2003).
Two bounding estimate climate scenarios (warm throughout the year and cold throughout
the year) were considered, as well as three exposure time periods: short-term (one day to one
month), intermediate-term (one month to six months), and average lifetime exposure (6 years over
a 75 year lifetime). SHEDS-Wood calculated the predicted exposure (and dose) to arsenic and
chromium using age and gender representative time-location activity data for children ages 1-6
years old (Zartarian et al., 2003).
It should be noted that this risk assessment report does not address certain high risk
groups (e.g., children with autism, Down’s syndrome). This issue is, however, addressed
qualitatively in the probabilistic exposure assessment (Zartarian et al., 2003). Exposures to
arsenic for children with pica soil ingestion behavior were assessed. In addition, it should be
noted that the probabilistic exposure assessment developed by Zartarian et al. (2003) contains
additional exposure scenarios (e.g., Tables 32 and 34) that were not included in this risk
assessment.
The ADDs and LADDs derived from the SHEDS-Wood report (Zartarian et al., 2003) are
summarized in Tables 3-1 to 3-10. Tables 3-1 through 3-10 summarize the means, medians, 95
percentiles, and 99 percentiles for arsenic ADDs/LADDs and Cr(VI) ADDs. These exposure
doses were used to generate MOEs and cancer risks for the risk characterization (see Chapter
5.0) and risk reduction impact (see Chapter 6.0) chapters. The ADDs and LADDs are also
presented later in probabilistic risk tables in Chapters 5 and 6 along with the corresponding MOEs
and cancer risks. With the exception of the Cr(VI) ADDs, Zartarian et al. (2003) presented all of
the exposure doses used to generate these tables, and the footnotes in Tables 3-1 to 3-10 indicate
which corresponding table from Zartarian et al. (2003) was referenced. For Cr(VI), the footnotes
reference the ADDs that are presented later in Chapter 5.
Tables 3-1 to 3-2 present ADDs for arsenic and chromium for short- and intermediateterm exposures. These tables attempt to capture the population of children that play on both
playsets and decks in warm and cold climate settings. Tables 3-3 to 3-4 present ADDs for
children exposed to playsets only. Table 3-5 presents arsenic ADDs for children with a special
3-2
sensitivity of pica soil ingestion behavior in warm climates. Arsenic exposures for warm climates
represent the highest risk concern for pica soil ingestion behavior. Table 3-6 presents the LADDs
for arsenic. These tables present the risks for the population of children that play on playsets and
decks, and playsets only based on warm and cold climate settings. Tables 3-7 to 3-9 are the
LADDs for arsenic (used later in Chapter 5) and represent reductions in arsenic exposure from
hand washing, and coating CCA-treated wood with sealants (assumes a hypothetical 90% and
99.5% reduction for typical sealants), or both hand washing and sealants combined. Only LADDs
for the warm climate settings were assessed. Table 3-10 presents the exposure doses for arsenic
using the Wester et al. (2003) dermal absorption factor for arsenic (i.e., 0.01 percent). This is
considerably lower than the default dermal absorption factor recommended by the FIFRA SAP, a
value in the range of 2-3 percent. Risks for these scenarios are provided later in Chapter 5.
Table 3-1. Arsenic ADDs (mg/kg/day) - Playsets and Decksa
Mean
Time Frameb
a
b
c
d
Median
95%ile
99%ile
Warm
Cold
Warm
Cold
Warm
Cold
Warm
Cold
Short c
1.3E-4
6.7E-5
6.5E-5
2.5E-5
4.7E-4
2.2E-4
9.5E-4
7.0E-4
Intermediate d
1.3E-4
7.0E-5
6.8E-5
3.1E-5
4.5E-4
2.4E-4
9.6E-4
5.9E-4
The ADDs represent the mean, median, 95%ile, and 99%ile total doses for both warm and cold climate residue and soil
data for playsets and decks.
Time frame considers short-term (1 day to 1 month) and intermediate-term (1-6 months) exposures.
Data for short-term warm climate ADDs are based on the results of Table 18 in Zartarian et al. (2003). Data for shortterm cold climate ADDs are based on the results of Table 19 in Zartarian et al. (2003). Also refer to Table 5-6 and Table
5-7 for short-term ADDs for warm and cold climates.
Data for intermediate-term warm ADDs are based on the results of Table 16 in Zartarian et al. (2003). Data for
intermediate-term cold ADDs are based on the results of Table 17 in Zartarian et al. (2003). Also refer to Table 5-11 and
Table 5-12 for intermediate-term ADDs for warm and cold climates.
3-3
Table 3-2. Chromium(VI) ADDs (mg/kg/day) - Playsets and Decks a,b
Mean
a
b
c
d
e
Median
95%ile
99%ile
Time
Framec
Warm
Cold
Warm
Cold
Warm
Cold
Warm
Cold
Short d
1.0E-5
2.5E-6
2.5E-7
2.9E-8
3.9E-6
1.0E-6
1.3E-5
3.7E-6
Intermediate e
9.1E-6
2.3E-6
2.3E-7
3.5E-8
3.5E-6
8.9E-7
1.0E-5
3.4E-6
The exposure doses represent soil ingestion exposure only for Cr(VI).
These ADDs represent the mean, median, 95%ile, and 99%ile total doses for both warm and cold climate soil ingestion
data for playsets and decks.
Time frame considers short-term (1 day to 1 month) and intermediate-term (1-6 month) exposures.
Data for short-term ADDs were recalculated based on soil ingestion only exposures and a 10% adjustment to
chromium(total) to account for Cr(VI). Refer to Table 5-8 and Table 5-9 for short-term ADDs for warm and cold climates.
Data for intermediate-term ADDs were recalculated based on soil only exposures and a 10% adjustment to
chromium(total) to account for Cr(VI). Refer to Table 5-13 and Table 5-14 for intermediate-term ADDs for warm and
cold climates.
Table 3-3. Arsenic ADDs (mg/kg/day) - Playsets Onlya
Mean
Time Frameb
a
b
c
d
Median
95%ile
99%ile
Warm
Cold
Warm
Cold
Warm
Cold
Warm
Cold
Short c
8.4E-5
4.3E-5
3.0E-5
1.4E-5
2.9E-4
1.6E-4
8.2E-4
4.6E-4
Intermediate d
5.9E-5
3.7E-5
2.8E-5
1.1E-5
2.3E-4
1.2E-4
4.3E-4
3.9E-4
The ADDs represent the mean, median, 95%ile, and 99%ile total doses for both warm and cold climate soil ingestion data
for playsets only.
Time frame considers short-term (1 day to 1 month) and intermediate-term (1-6 month) exposures.
Data for short-term warm climate ADDs are based on Table 18 in Zartarian et al. (2003). Data for short-term cold climate
ADDs were based on Table 19 in Zartarian et al. (2003). Also refer to Table 5-6 and Table 5-7 for short-term ADDs for
warm and cold climates.
Data for intermediate-term warm ADDs are based on Table 16 in Zartarian et al. (2003). Data for intermediate-term cold
climate ADDs are based on Table 17 in Zartarian et al. (2003). Also refer to Table 5-11 and Table 5-12 for intermediateterm ADDs for warm and cold climates.
3-4
Table 3-4. Chromium(VI) ADDs (mg/kg/day) - Playsets Only a,b
Mean
Time Framec
a
b
c
d
e
Median
95%ile
99%ile
Warm
Cold
Warm
Cold
Warm
Cold
Warm
Cold
Short d
9.7E-6
1.8E-6
1.8E-7
1.5E-8
4.3E-6
6.9E-7
1.5E-5
3.0E-6
Intermediate e
8.9E-6
1.3E-6
1.6E-7
1.4E-8
3.5E-6
6.0E-7
1.6E-5
1.8E-6
The exposure doses represent soil ingestion exposure only for Cr(VI) for playsets only.
The ADDs represent the mean, median, 95%ile, and 99%ile total doses for both warm and cold climate soil ingestion data
for playsets only.
Time frame considers short-term (1-day to 1-month) and intermediate-term (1-6 month) exposures.
Data for short-term ADDs are recalculated based on soil only exposures and a 10% adjustment to chromium(total) to
account for Cr(VI). Refer to Table 5-8 and Table 5-9 for short-term ADDs for warm and cold climates.
Data for intermediate-term ADDs were recalculated based on soil only exposures and a 10% adjustment to
chromium(total) to account for Cr(VI). Refer to Table 5-13 and Table 5-14 for intermediate-term ADDs for warm and
cold climates.
Table 3-5. Arsenic ADDs (mg/kg/day) - Pica Ingestiona
a
Scenario
Mean
Median
95%ile
99%ile
Playsets and decks
3.1E-4
1.5E-4
1.0E-3
1.6E-3
Playsets only
2.3E-4
9.9E-5
7.7E-4
2.2E-3
The ADDs represent the mean, median, 95%ile, and 99%ile total doses for warm climate soil data. Data for short-term
warm climate ADDs are based on Table 33 in Zartarian et al. (2003).
Table 3-6. Arsenic LADDs (mg/kg/day)a
Mean
Scenario
a
Median
95%ile
99%ile
Warm
Cold
Warm
Cold
Warm
Cold
Warm
Cold
Playsets and
decks
1.1E-5
6.0E-6
6.1E-6
2.9E-6
3.9E-5
2.1E-5
8.4E-5
4.4E-5
Playsets only
6.4E-6
3.2E-6
3.0E-6
1.5E-6
2.3E-5
1.2E-5
6.5E-5
2.4E-5
The LADDs represent the mean, median, 95%ile, and 99%ile total doses for playsets and decks and for playsets only in
cold and warm climates. Data for warm climate LADDs are based on Table 14 in Zartarian et al. (2003). Data for cold
climate LADDs are based on Table 15 in Zartarian et al. (2003). Also refer to Table 5-16 for LADDs for warm climates
and Table 5-17 for LADDs for cold climates.
3-5
Table 3-7. Arsenic LADDs (mg/kg/day) - Mitigation with Sealanta
Mean
Scenario
a
b
c
Median
95%ile
99%ile
Moderate
(90%)b
Max.
(99.5%)c
Moderate
(90%)b
Max.
(99.5%)c
Moderate
(90%)b
Max.
(99.5%)c
Moderate
(90%)b
Max.
(99.5%)c
Playsets
and
decks
1.8E-6
8.0E-7
1.1E-6
3.6E-7
5.6E-6
2.9E-6
1.0E-5
7.8E-6
Playsets
only
9.0E-7
5.5E-7
5.4E-7
2.2E-7
3.0E-6
2.2E-6
5.7E-6
4.6E-6
The LADDs represent the mean, median, 95%ile, and 99%ile total dose for playsets and decks and for playsets only in
warm climates, assuming reduction of sealants.
Moderate reduction (assumes 90% reduction with sealant for warm climates only). Data for warm climate LADDs are
based on Table 37 in Zartarian et al. (2003). Also refer to Table 6-5 for LADDs for warm climates.
Maximum reduction (assumes 99.5% reduction with sealant for warm climates only). Data for warm climate LADDs are
based on Table 38 in Zartarian et al. (2003). Also refer to Table 6-6 for LADDs for warm climates.
Table 3-8. Arsenic LADDs (mg/kg/day) - Mitigation with Hand Washing a
a
Scenario
Mean
Median
95%ile
99%ile
Playsets and
decks
8.4E-6
4.8E-6
2.7E-5
7.0E-5
Playsets only
3.7E-6
2.1E-6
1.2E-5
2.0E-5
The LADDs represent the mean, median, 95%ile, and 99%ile total dose for playsets and decks and playsets only in warm
climates, assuming reduction by sealants. Data for warm climate LADDs were based on Table 39 in Zartarian et al.
(2003). Also refer to Table 6-8 for LADDs for warm climates.
3-6
Table 3-9. Arsenic LADDs (mg/kg/day) - Mitigation with Hand Washing and Sealant a
Mean
Scenario
a
b
c
Median
95%ile
99%ile
Moderate
(90%)b
Max.
(99.5%)c
Moderate
(90%)b
Max.
(99.5%)c
Moderate
(90%)b
Max.
(99.5%)c
Moderate
(90%)b
Max.
(99.5%)c
Playsets
and
decks
1.6E-6
9.2E-7
8.9E-7
3.4E-7
5.2E-6
3.2E-6
8.4E-6
1.1E-5
Playsets
only
9.8E-7
5.7E-7
5.2E-7
2.0E-7
3.2E-6
2.5E-6
6.2E-6
4.7E-6
The LADDs represent the mean, median, 95%ile, and 99%ile total dose for playsets and decks and for playsets only in
warm climates, assuming reduction of sealants.
Moderate reduction assumes 90% reduction with sealant and hand washing. Data for warm climate LADDs are based on
Table 40 in Zartarian et al. (2003). Also refer to Appendix C.
High reduction assumes 99.5% reduction with sealant and hand washing. Data for warm climate LADDs are based on
Table 41 in Zartarian et al. (2003). Also refer to Appendix C.
Table 3-10. Arsenic LADDs (mg/kg/day) - Using 0.01% Dermal Absorptiona
Mean
Scenario
a
Median
95%ile
99%ile
Warm
Cold
Warm
Cold
Warm
Cold
Warm
Cold
Playsets and
decks
7.9E-6
5.4E-6
4.5E-6
2.7E-6
2.7E-5
2.1E-5
6.4E-5
4.3E-5
Playsets only
4.0E-6
2.9E-6
2.0E-6
1.1E-6
1.2E-5
1.0E-5
3.3E-5
2.7E-5
The LADDs represent the mean, median, 95%ile, and 99%ile total doses for playsets and decks and for playsets only for
warm and cold climates, assuming reduction using a 0.01% dermal absorption factor. Data for warm climate LADDs are
based on Table 35 in Zartarian et al. (2003). Data for cold climate LADDs are based on Table 36 in Zartarian et al.
(2003). Also refer to Table 5-19 for LADDs for warm climates and Table 5-20 for LADDs for cold climates.
3-7
4.0 HAZARD ASSESSMENT
The purpose of the hazard assessment is to identify available evidence regarding the
potential for the chemical of concern to cause adverse effects to the potential receptor (individual)
and to provide, where possible, an estimate of the relationship between the extent of exposure to
the chemical of concern and increased likelihood and/or severity of the adverse effects.
For noncancer toxic effects, available toxicology data are reviewed and no-observed
adverse effect levels (NOAELs) and lowest observed adverse effect levels (LOAELs) are
developed for each study. Subsequently, the reviewed data for the chemical of concern are
presented to a committee of scientists within OPP who reach concurrence on toxicology
endpoints that best represent the toxic effects expected from various routes of exposure and
durations of exposure. Endpoints are selected for non-dietary exposures to represent short-term
(1-30 days), intermediate-term (30-180 days), and long-term exposure scenarios, as needed. In
addition, incidental oral exposure endpoints are selected for short-term and intermediate-term
exposure durations to represent ingestion of the chemical of concern residues that may occur from
hand-to-mouth behaviors. In general, toxicity endpoint selection should, to the extent possible,
match the temporal and spatial characteristics of the exposure scenarios selected for use in the risk
assessment. These endpoints are then used in conjunction with exposure values to calculate risks
associated with various types of exposure, depending upon the uses of the chemical of concern
(McMahon and Chen, 2003).
For carcinogenic effects of a chemical, a slope factor (SF), also know as potency factor, is
derived. Slope factors are developed based on a dose-response curve for carcinogenicity of the
specific chemicals. The slope factors are developed from human and animal studies and are
designed to be health protective. The SF is used to estimate an upper-bound probability of an
individual developing cancer as a result of exposure to a potential carcinogen. Carcinogens with
EPA-derived slope factors are also given an EPA weight-of-evidence classification, whereby,
potential carcinogens are grouped according to the likelihood that the chemical is a human
carcinogen, depending on the quality and quantity of carcinogenic potency data for a given
chemical.
For the current CCA risk assessment, arsenic and chromium were considered as the
primary chemicals of concern. The current policy, Conditions for Acceptance and associated
principles are not intended to apply to dose-response evaluations for human health risk
assessments until this application has been studied further (Agency Policy Document, 5/15/1997)
(U.S. EPA, 1997a). Currently, OPP does not have the Guidance to perform the probabilistic
analysis of toxicity endpoints. For this risk assessment, OPP used the endpoints developed by
U.S. EPA, (McMahon and Chen, 2003), which are provided in Appendix A. These endpoints
were developed using guidance provided by the FIFRA SAP (U.S., EPA, 2001c). As stated in
the Agency Policy Document, 5/15/97 (U.S. EPA, 1998), “For human health risk assessments, the
4-1
application of Monte Carlo and other probabilistic techniques has been limited to exposure
assessments in the majority of cases. The current policy, Conditions for Acceptance and
associated guiding principles are not intended to apply to dose-response evaluations for human
health risks assessment until this application of probabilistic analysis has been studied further.”
Currently, OPP does not have guidance available to perform the probabilistic analysis of toxicity
endpoints. According to Agency policy, endpoints used in assessments should be consistent with
the exposure of concern (acute, subchronic, chronic), and should be those selected by the HED
Hazard Identification Assessment Review Committee (HIARC), or selected in accordance with
the Draft Toxicology Endpoint Selection Process: A Guidance Document, presented to the SAP
in February 1997. Thus, point estimates have been used to characterize toxicity for the CCA risk
assessment. Toxicology endpoints for both inorganic arsenic and chromium have been selected for
the residential exposure assessment and are presented in Sections 4.1 and 4.2, respectively.
Summary tables are provided in Section 4.3.
It also should be noted that the studies from Ginsberg (2003) and other researchers, and
the recent work on early-life exposures by ORD in the Draft Final Guidelines for Carcinogenic
Risk Assessment (U.S. EPA, 2003a) and Supplemental Guidance for Assessing Cancer for
Environment Assessment (U.S. EPA, 2003b), discussed the criteria for assessing early-life
exposure. A discussion of early-life exposures to arsenic is presented in Section 4.4. In addition,
a brief discussion of the relative bioavailabilities and dermal absorption values of arsenic and
chromium in surface residues and soil are presented in Sections 4.5 and 4.6, respectively.
4.1
Arsenic
Based on the registered use of CCA-treated lumber for fencing and decking materials in
residential settings, both incidental oral and dermal exposures are expected. The studies selected
for short- and intermediate-term incidental oral exposure were the human case reports of
Franzblau and Lilis (1989) and Mizuta et al. (1956) (see Appendix A). The oral LOAEL of 0.05
mg/kg/day was selected, based on facial edema, gastrointestinal symptoms, neuropathy, and skin
lesions observed at this dose level (see Appendix A). A Margin of Exposure (MOE) of 30 should
be applied to the oral LOAEL. This value consists of a 10x factor for intraspecies variation and a
3x factor for extrapolating from a LOAEL to a NOAEL observed at the LOAEL of 0.05
mg/kg/day.
Since there were no appropriate dermal studies, the same studies selected for short- and
intermediate-term incidental oral exposure were selected for short- (1-30 days ) and intermediate(30-180 days) term dermal exposure scenarios (see Appendix A). OPP did not develop an
exposure assessment for long-term exposures (see Zartarian et al., 2003). Thus, the oral LOAEL
of 0.05 mg/kg/day was selected for dermal exposures, based on facial edema, gastrointestinal
symptoms, neuropathy, and skin lesions observed at this dose level. The dermal absorption factor
approach used in this assessment does not use a point estimate but uses a range of reported values
4-2
from the Wester et al. (1993) study which was recommended by the FIFRA Scientific Advisory
Panel (U.S. EPA, 2001c). The same MOE of 30 was also selected for dermal exposure. No longterm incidental oral or dermal exposures are expected from residential exposure to arsenic in
CCA-treated lumber. At the advice of the SAP, EPA decided not to quantify inhalation exposure
to metals since such exposure would be minimal (U.S. EPA, 2001c).
For this risk assessment, an oral cancer slope factor of 3.67 (mg/kg/day)-1 was used. This
value is based on the Agency’s risk assessment associated with inorganic arsenic in drinking water
presented in 2000 (U.S. EPA, 2001e, personal communication with Andrew Schulman). It is
consistent with the slope factor used by the Office of Water for the arsenic MCL. See Appendix
A for more details regarding the carcinogenic slope factor used. Following the risk assessment
associated with inorganic arsenic in drinking water, which was presented in 2000, EPA asked the
National Research Council (NRC) to meet again to: (1) review EPA’s characterization of
potential human health risks from ingestion of inorganic arsenic in drinking water; (2) review the
available data on the carcinogenic and noncancer effects of inorganic arsenic; (3) review the data
on the metabolism, kinetics and mechanism(s)/mode(s) of action of inorganic arsenic; and (4)
identify research needs to fill data gaps. In 2001, NRC published an update to the 1999 NRC
report (NRC, 1999) and concluded that: (1) arsenic-induced bladder and lung cancers still should
be the focus of arsenic-related cancer risk assessment; (2) southwestern Taiwan data are still the
most appropriate for arsenic-related cancer risk assessment; and (3) present modes of action data
are not sufficient to depart from the default assumption of linearity. However, the 2001 NRC
update made specific recommendations with respect to the overall cancer risk estimates. The
Agency is currently considering these recommendations and their potential impact on the cancer
potency estimate. Based on the Agency’s considerations of these recommendations, the current
proposed cancer potency number may change in the final version of this risk assessment.
4.2
Chromium
For chromium, hazard data clearly show that Cr(VI) demonstrates more significant
toxicity than Cr(III). During pressure treatment of wood, CCA undergoes a fixation process
where it is initially absorbed into the cellulosic and lignin structures of the wood. Chromium, in
the form of Cr(VI), attaches itself to the ‘carboxylic groups’of the cellulosic structure and
converts into Cr(III) (U.S. EPA, 2001c). More recent studies by the ACC and RTI International
indicate that Cr(III) is the main component in CCA pressure-treated wood (RTI International,
2003; Nico et al., 2003; Cooper, 2003). Based on the non-detectable results of Cr(VI) in the
CCA-treated wood in the Cooper (2003) and RTI International (2003) studies, the Agency felt
that it was not credible to assign Cr(VI) toxicity endpoints to total Cr surface residue results,
since evidence indicates most of the Cr wood surface residues in wood are primarily Cr(III).
Therefore, OPP did not assess the risks from incidental ingestion exposures in wood surface
residues for children in this assessment. However, the Agency felt that it would be appropriate to
assess soil ingestion exposure to Cr(VI) (dermal toxicity endpoints were not identified for
4-3
Cr(VI)). Therefore, toxicity information to assess soil ingestion exposures to Cr(VI) was
required. As discussed in the Exposure Chapter (3.0), the total chromium doses from SHEDSWood for soil ingestion were multiplied by 0.10 (10%) to estimate a Cr(VI) equivalent dose.
This was done for both short- and intermediate-term chromium doses. Toxicity endpoints for
Cr(VI) were then applied to the Cr(VI) equivalent doses to evaluate Cr(VI) risks.
Based on the registered use of CCA-treated lumber for fencing and decking materials in
residential settings, incidental oral exposure to chromium is expected, based on potential ingestion
of soil contaminated with chromium as a result of leaching from wood. The study selected for
short- and intermediate-term incidental oral exposure was a developmental toxicity study in the
rabbit conducted by Tyl et al. (1991) and submitted to the Agency under
MRID #42171201 (see Appendix A for details regarding this study). Based on the Tyl et al.
(1991) study, a maternal NOAEL of 0.5 mg/kg/day and a LOAEL of 2.0 mg/kg/day were
selected as the short- and intermediate-term toxicity endpoints, based on the increased incidence
of maternal mortality and decreased body weight gain (see Appendix A for more description of
the studies used to develop the toxicity endpoints). An MOE of 100 was assigned by OPP for this
endpoint (McMahon and Chen, 2003).
The U.S. EPA (1998b) IRIS document on Cr(VI) states that “chromium is one of the
most common contact sensitizer in males in industrialized countries and is associated with
occupational exposures to numerous materials and processes.” In addition, it further states that
“dermal exposure to chromium has been demonstrated to produce irritant and allergic contact
dermatitis.” It was determined by the OPP HIARC that quantification of hazard from dermal
exposure is not possible for chromium, due to the significant dermal irritation and sensitization
observed. Therefore, no endpoints were determined by HIARC for Cr(VI) from dermal
exposures. Dermal irritation and dermal sensitization are the primary concern for the dermal
exposure route.
The members in the October 23-25, 2001, FIFRA SAP meeting agreed that the Agency
should not consider the inhalation route of exposure for chromium in the risk assessment.
4.3
Summary Tables
All the selected non-cancer toxicological endpoints used for arsenic are summarized in
Table 4-1. Table 4-2 presents the toxicological endpoints for Cr(VI). For child exposures in this
assessment, only the incidental ingestion and dermal exposure pathways were considered.
4-4
Table 4-1.
Toxicological Endpoints for Assessing Exposures/Risks to Arsenic (V)
EXPOSURE
SCENARIO
Incidental Short- and
Intermediate- Term Oral
DOSE
(mg/kg/day)
a
LOAEL=
0.05
ENDPOINT
STUDY
Based on edema of the face, gastrointestinal,
upper respiratory, skin, peripheral and
neuropathy symptoms
Franzblau et al. (1989) and
Mizuta et al. (1956)
Based on edema of the face, gastrointestinal,
upper respiratory, skin, peripheral and
neuropathy symptoms
Franzblau et al. (1989) and
Mizuta et al. (1956)
MOE = 30
Dermal Short- and
Intermediate-Term a,b
LOAEL=
0.05
MOE = 30
Carcinogenicity - Oral
Q1* = 3.67
Internal organ cancer (liver, lung and
Chronic epidemiological oral
Ingestion
(mg/kg/day) -1
bladder)
study on humans
(Oral and Dermal Risks)
Note:
a
MOE = Margin of Exposure; NOAEL = No observed adverse effect level; and LOAEL = Lowest observed
adverse effect level.
b
The dermal absorption factor approach used in this assessment does not use a point estimate but uses a
range of reported values from the Wester et al. (1993) study which was recommended by the FIFRA
Scientific Advisory Panel. The dermal absorptions are incorporated into the SHEDs-Wood model.
Table 4-2. Toxicological Endpoints for Assessing Exposures/Risks to Chromium (VI)
EXPOSURE
SCENARIO
DOSE
(mg/kg/day)
ENDPOINT
Increased mortality and decreased body
weight gain in dams at 2.0 mg/kg/day.
STUDY
Incidental Short- and
Intermediate- Term
Oral a
NOAEL= 0.5
Developmental/Rabbit
Tyl et al. (1991)
Dermal Short- and
Intermediate-Term b
Because dermal irritation and dermal sensitization are the primary concern through the dermal
exposure route, no toxicological end-point is selected for use in assessing dermal exposure risks
to chromium.
MOE = 100
Note:
a
b
4.4
MOE = Margin of Exposure; NOAEL = No observed adverse effect level; and LOAEL = Lowest observed
adverse effect level.
An oral NOAEL is used for the toxicity endpoint for soil ingestion. Dermal absorption factor of 1% is
incorporated into SHED S-Wood model.
Early-Life Exposures
Ginsberg (2003) mentions that for “a vast majority of chemicals that have cancer potency
estimates on IRIS, the underlying database is deficient with respect to early-life exposures.”
4-5
Ginsberg (2003) concluded that based on the results of his study “short-term exposures in early
life are likely to yield a greater tumor response than short-term exposures in adults, but similar
tumor response when compared to long-term exposures in adults.” The risk attributable to earlylife exposure often appears modest compared with the risk from lifetime exposure. It can be about
10-fold higher than the risk from an exposure of similar duration occurring later in life (Ginsberg,
2003).
ORD has recently published Draft Final Guidelines for Carcinogen Risk Assessment
(U.S. EPA, 2003a) This document mentions the need to address early-life exposures from
carcinogens. In addition, ORD has also published an external review draft document entitled the
Supplemental Guidance for Assessing Cancer Susceptibility from Early Life Exposure to
Carcinogens (U.S. EPA, 2003b). U.S. EPA (2003b) presents an approach for assessing cancer
susceptibility from early-life exposure to carcinogens.
Much toxicity are available on arsenic; however, the data needed to account for an
accurate representation of early-life exposure to arsenic appears to be insufficient. For example,
the arsenic, the National Resource Council (NRC, 2001) reports that “few studies of the effects of
arsenic on reproduction and development had been published” (NRC, 2001). NRC also
concluded “that although a large amount of research is available on arsenic’s mode of action, the
exact nature of the carcinogenic action is not clear” (NRC, 2001). Finally, NRC concluded that
inorganic arsenic and its metabolites have been shown to induce chromosomal alterations and
large deletion of mutations, but not point mutations.
Although there is some new evidence indicating that exposure to arsenic from drinking
water during pregnancy may be associated with decreased birth weights of newborns (Hopenhayn,
2003) and may increase the cancer incidence of the child in the later stage of life (Waalkes, 2003),
the data needed to account for an accurate representation of early-life exposure of arsenic appears
to be insufficient (NRC, 2001). However, because the cancer slope factor used in this cancer risk
assessment is derived from the epidemiology study using the Southwestern Taiwan data, it is
generally believed that the sensitive population exposed to inorganic arsenic through drinking
water during the most sensitive period of time is already included in the exposed population.
Therefore, an adjustment factor does not appear to be appropriate in the cancer risk assessment
associated with arsenic exposure.
4.5
Relative Bioavailability
The absorption of a chemical of concern is dependent on the matrix to which it is exposed.
It is generally assumed that the absorption of the chemical of concern from the gastrointestinal
tract is nearly complete. The toxicological endpoints were selected based on the administered
dose, not the absorbed dose. However, when the chemical is in a different matrix, it may have a
different absorption rate because it may be present in water-insoluble forms or interact with other
4-6
constituents in the matrix. The relative bioavailability of the chemical of concern, after it is
exposed (water vs. soil), was defined as the percentage of the chemical of concern absorbed into
the body of a soil-dosed animal compared to that of an animal receiving a single dose of the
chemical of concern in an aqueous solution.
The issue of arsenic and chromium relative bioavailability has already been discussed in the
October 23-25, 2001, FIFRA SAP Meeting (see comments in Appendix F). The
recommendations of the FIFRA SAP for both arsenic and chromium have been incorporated into
the SHEDS-WOOD document to develop ADDs and LADDs (Zartanian et al., 2003). A
summary of relative bioavailability studies for arsenic is presented in Appendix E.
Arsenic
Zartarian et al. (2003) used data from ACC (2003a; 2003b) to determine the relative
bioavailability for arsenic in the matrix of concern (either CCA-treated wood surface residue or
soil collected from areas around CCA-treated wood) vs. arsenic in water. According to Zartarian
et al. (2003), the ACC data were fitted in SHEDS-Wood to a beta distribution, with a mean
relative bioavailability of 0.273 (27.3%) for CCA-treated wood surface residue vs. arsenic in
water. For arsenic in soil collected from an area close to CCA-treated wood, Zartarian et al.
(2003) fitted the ACC (2003a) data to a beta distribution, with a mean relative bioavailability of
0.476 (47.6%).
Chromium
Zartarian et al. (2003), per FIFRA SAP (U.S. EPA, 2001c) recommendations, assumed a
relative bioavailability of 100% for both chromium surface residues and soil vs. chromium in
water.
4.6
Dermal Absorption
Arsenic
Although OPP reported a point estimate for dermal absorption from Wester et al. (1993)
in the hazard assessment (see Appendix A), the dermal absorption factor approach used in the
Zartarian et al. (2003) probabilistic exposure assessment, and in this risk assessment, used a range
of reported values from Wester et al. (1993). The distribution of values selected from SHEDSWood is described in more detail in the SHEDS-Wood probabilistic assessment (Zartarian et al.,
2003). It should be noted that the approach used in SHEDS-Wood was consistent with the
recommendations of the FIFRA Scientific Advisory Panel (U.S. EPA, 2001c). Wester et al.
(1993) in vivo results with monkeys ranged from 2.0% to 6.4%. In the OPP 2001 deterministic
assessment, OPP used 6.4% and later also used this for the occupational risk assessment in the
4-7
reregistration document. The 2001 SAP recommended a value in the range of 3%.” For the
SHEDS-Wood assessment, ORD fit a triangular distribution to the Wester et al. (1993) data
(Zartarian et al., 2003). Zartarain et al. (2003) also went on to say that “It was important to note
that because of dermal removal processes (hand washing, bathing, and hand mouthing), the
modeled daily absorption rate is lower than the user-specified value. For a 3% per day input, the
actual amount absorbed is predicted at about 1% per day. This is consistent with the SAP
2001(U.S. EPA, 2001c) comment that the 2%-3% from the monkey studies may be too high
because of real-world removal processes from skin noted above” (Zartarian et al., 2003).
Chromium
As noted in Section 4.2, dermal irritation and dermal sensitization are still the primary
concern for the dermal exposure route. The FIFRA SAP noted that “it is unlikely that sufficient
chromium could penetrate the skin and enter the circulation to cause systemic effects from dermal
exposure. Skin penetration for chromium is estimated to be 1%. It is usually assumed that the
contribution to systemic effects from dermal exposure is not likely to be significant relative to oral
exposure.”
4-8
5.0 RISK CHARACTERIZATION
5.1
Introduction
The objective of the risk characterization was to integrate toxicity data (see Chapter 4.0)
with the results of the exposure assessment (Chapter 3.0) to evaluate potential human health
impacts to children who are exposed to arsenic and chromium residues while playing on or near
CCA-treated wood playgrounds and decks. Children can be exposed to arsenic and chromium
residues via hand-to-mouth ingestion and dermal absorption of residues in wood and soil. This
chapter presents the incremental risks from exposure to CCA-treated wood and does not address
risks from exposure to all sources of arsenic and chromium in the environment. The probabilistic
exposure assessment (Zartarian et al., 2003) used for this risk assessment was specific for
exposure to surface residues from treated wood and surrounding soils.
This chapter presents a probabilistic risk characterization. Distributions were used for
input variables of the exposure dose algorithm, and the output of the exposure assessment was a
distribution of risks across all members of the population. This exposure distribution was
combined with toxicity data to provide a risk distribution for members of the exposed population.
A hypothetical example of a cumulative distribution function for cancer risk is shown in
Figure 5-1. The x-axis of Figure 5-1 represents the excess lifetime cancer risk level and the y-axis
represents the cumulative probability of the cancer risk level within the hypothetical population.
The figure also shows various landmarks along the distribution curve, such as the 50th, 90th, 95th
percentiles, etc. For example, in Figure 5-1, the 95th percentile corresponds to a cancer risk of
1.2E-06 and the 50th percentile corresponds to a cancer risk of 4.1E-07 (U.S. EPA, 2001d).
Risks due to exposure to CCA-treated wood were evaluated for noncancer and cancer
effects. Cancer risk refers to the probability of increased cancer incidence resulting from exposure
to proven or suspected carcinogenic chemicals. Cancer risk is generally expressed in scientific
notation (e.g., an individual excess lifetime risk of 1 in 10,000 is represented as 1 x 10-4 or 1E-04).
The impact of carcinogenic chemicals was assessed by combining chemical-specific estimates of
doses and toxicity values (slope factors) and comparing the estimated risks to specified risk levels.
Noncancer effects were evaluated by calculating the ratio of the NOAEL or the LOAEL to the
projected or estimated intake (i.e., dose). The resulting value is termed the MOE. The larger the
MOE, the more unlikely it is that a noncancer adverse effect would occur. EPA established a
guidance MOE value of 30 for arsenic and 100 for chromium (Cr(VI)) to account for the
uncertainties associated with the toxicity data and other factors. Some of the 2001 SAP Panel
members cautioned that when the calculated MOE is below the acceptable MOE, it does not
necessarily mean that health effects will occur. The presence or absence of health effects should
not be drawn solely on whether there calculated MOEs exceed the acceptable MOEs (U.S. EPA,
5-1
2001c). Arsenic risks were evaluated for noncancer and cancer effects and Cr(VI) risks were
evaluated for noncancer effects only.
Figure 5-1: A Cumulative Distribution Function (CDF) for Cancer Risk
The interpretation of results in this risk assessment is somewhat unique. In traditional risk
assessments, the intent is to inform risk managers whether or not a pre-established health effects
threshold is exceeded. For example, in traditional cancer risk assessment, 1 x 10-6 is considered
by OPP as the threshold of concern for residential scenarios. If this risk is exceeded, the risk
manager then decides which remedial or mitigation measures are to be implemented to reduce the
risks to an acceptable level. The intent of this present probabilistic risk assessment is slightly
different. The goal of this risk assessment is to present the SAP with the calculated arsenic cancer
risks to children (age 1-6) exposed to CCA-treated playsets and decks using a probabilistic risk
analysis. It also identifies methods (e.g., sealants and hand washing) which can reduce the arsenic
5-2
cancer risks to children. However, there is no concluding statement regarding the percentiles of
the distribution or point estimates (e.g., mean, 50th , 90th , 95th, etc) at which risk management
decisions will be made. OPP intends to provide recommendations on how risk managers should
interpret the results of this risk assessment, after receiving technical comments from the FIFRA
SAP on evaluating probabilistic risk distributions. OPP will carefully consider the FIFRA SAP’s
comments on this issue.
5.2
Results
Noncancer MOEs and cancer risks were generated based on the exposure doses calculated
by the SHEDS-Wood model (Zartarian et al., 2003), as summarized in Chapter 3 of this
document, and the selected toxicological endpoint doses described in Chapter 4 of this document.
Exposure doses were generated for the following:
•
•
•
•
•
Two exposure routes - dermal and oral;
Three durations - short, intermediate, and lifetime;
Two sources of exposure - playset only, and playset and deck;
Two climates - warm and cold; and
Two chemicals - arsenic and chromium.
The exposed population of interest was children; ages 1 to 6 years. The durations of exposure
were defined as short (1 day to 1 month); intermediate (1-6 months); and lifetime (6 years
averaged over 75 years).
Table 5-1 presents a summary of the risk assessment results for noncancer and cancer
risks. This table indicates which exposure conditions exceed specified risk levels. The summary
is presented according to exposure scenario (i.e., source of exposure, climate, and duration of
exposure for noncarcinogens). For the noncancer effects of arsenic, estimated MOEs were found
to be greater than the guidance MOE of 30 for all exposures at the 99.6th percentile. For the
noncancer effects of chromium, none of the exposure scenarios evaluated had estimated MOEs
that fell below the target MOE of 100.
Cancer risks from arsenic were compared to the three levels of risk: 10-6, 10-5,
and 10 . Values reported in Table 5-1 are the cumulative probabilities above which the respective
risk level has been exceeded. For example, for exposure to playsets only in a warm climate, the
risk level of 10-6 was exceeded at the 3rd percentile; 97% of the SHEDS-Wood simulated
population had risks that exceeded 10-6. Cancer risks were found to be higher for the warm
climate scenario than the cold climate scenario, reflecting the increased exposure in a warm
climate. The 10-6 risk level was exceeded across all exposure scenarios at the very low end (i.e.,
less than 10th percentile) of the cumulative probability distribution. The 10-4 risk level was
-4
5-3
exceeded at the 90th percentile for exposure to playsets and decks in a warm climate and at the
97th percentile in a cold climate. For exposure to playsets only, the 10-4 level was exceeded at the
97th and 99th percentiles for warm and cold climates, respectively.
Table 5-1. Summary of Risk Assessment Results
Noncancer MOEs for Arsenic and Chromium
Source of
Exposure
Playset Only
Climate
Warm
Cold
Playset and Deck
Warm
Cold
Duration of
Exposure
Arsenic
MOE <30
Chromium
MOE <100
Short &
Intermediate
>99.6th Percentile
None
Short &
Intermediate
>99.6th Percentile
None
Cancer Risks for Arsenic a
Source of
Exposure
Playset Only
Playset and Deck
Cumulative Percentiles at Specified Risk Levels
Climate
10-6
10-5
10-4
Warm
3rd
47th
97th
Cold
9th
69th
99th
Warm
<1st
23rd
90th
Cold
2nd
49th
97th
a
Percentiles in this table represent the percent of the simulated population that have risks less than or equal to the stated risk
level; e.g., at 10-6, 3% of the population have risks less than 10-6 and 97% have risks greater than 10-6.
The remainder of this chapter presents the detailed results of the risk characterization.
Noncancer MOE results are presented in Section 5.2.1 and cancer risk results are presented in
Section 5.2.2.
5.2.1 Noncancer Effects
Noncancer effects were evaluated by calculating the ratio of the NOAEL or the LOAEL
to the projected or estimated intake (i.e., dose). The resulting value is termed the MOE. The
5-4
larger the MOE, the more unlikely it is that a noncancer adverse effect would occur. EPA
established an acceptable MOE value of 30 for arsenic and 100 for chromium (Cr(VI)) to account
for the uncertainties associated with the toxicity data and other factors. When the calculated MOE
is below the acceptable MOE, it does not necessary mean that health effects will occur. EPA uses
the MOE approach in a screening level capacity only. That is, firm conclusions on the presence or
absence of health effects should not be drawn solely on whether the calculated MOEs exceed the
acceptable MOEs. For arsenic, the LOAEL used was 0.05 mg/kg/day and the target MOE was
30. For Cr(VI), the NOAEL used was 0.5 mg/kg/day and the guidance MOE was 100. The
equation used for this calculation was:
MOE = NOAEL or LOAEL / ADD
Where:
NOAEL = No-Observed-Adverse-Effect Level (mg/kg/day);
LOAEL = Lowest-Observed-Adverse-Effect Level (mg/kg/day); and
ADD = Average Daily Dose (mg/kg/day).
Results are first presented for general population exposure and then for children with pica
behavior.
Tables 5-2 and 5-3 present the MOEs for children who play on outdoor CCA-treated
playsets only. The MOEs were calculated based on different exposure durations (short-term and
intermediate) and climates (warm and cold). Data were generated, and are presented in this
section, for the mean, median, 95th percentile, and 99th percentile of the distributions. Table 5-2
presents the arsenic MOEs for exposure to playsets only. The cold climate conditions were found
to have a larger MOE than for the warm climate conditions. For all conditions, the MOEs were
found to be substantially greater (minimum factor of 2) than the guidance MOE of 30. Table 5-3
presents the MOEs for Cr(VI) for the same scenarios.1 All the chromium MOEs were found to be
at least two orders of magnitude above the target MOE of 100.
1
Cr(VI) exposures/risks from soil ingestion were calculated by assuming 10 percent of
the chromium in soil was present as Cr(VI).
5-5
\
Table 5-2. Arsenic Noncancer MOEs - Playset Only
Arsenic (guidance MOE = 30)
LOAEL of 0.05 mg/kg/day
Mean
Time Frame
Median
95%ile
99%ile
Warm
Cold
Warm
Cold
Warm
Cold
Warm
Cold
Short
595
1,200
1,700
3,600
173
304
61
108
Intermediate
849
1,300
1,800
4,600
216
415
116
128
Table 5-3. Chromium (Cr(VI)) Noncancer MOEs - Playset Only
Chromium (VI) (guidance MOE = 100)
NOAEL of 0.5 mg/kg/day
Mean
Time Frame
Median
95%ile
99%ile
Warm
Cold
Warm
Cold
Warm
Cold
Warm
Cold
Short
7.2E+07
2.4E+08
1.7E+06
2.4E+07
1.0E+05
7.0E+05
3.1E+04
1.6E+05
Intermediate
2.2E+07
3.4E+08
1.8E+06
2.5E+07
1.3E+05
8.1E+05
3.0E+04
2.8E+05
The noncancer MOEs for exposure to both playsets and decks are presented in Table 5-4
for arsenic and Table 5-5 for chromium. The results for exposure to arsenic were similar to those
for playsets alone. The MOEs for all exposures were found to be greater than the guidance value
of 30. Cold climate conditions had higher MOEs (i.e., lower dose) than warm climate conditions.
None of the MOEs for chromium (Table 5-5) were below the guidance value; even at the 99 th
percentile, these MOEs were orders of magnitude above the guidance MOE of 100.
5-6
Table 5-4. Arsenic Noncancer MOEs - Playset and Deck
Arsenic (guidance MOE = 30)
LOAEL of 0.05 mg/kg/day
Time Frame
Mean
Median
95%ile
99%ile
Warm
Cold
Warm
Cold
Warm
Cold
Warm
Cold
Short
383
745
771
2,000
107
230
53
72
Intermediate
393
720
740
1,600
111
211
52
84
Table 5-5. Chromium (Cr(VI)) Noncancer MOEs - Playset and Deck
Chromium (VI) (guidance MOE = 100)
NOAEL of 0.5 mg/kg/day
Time Frame
Mean
Median
95%ile
99%ile
Warm
Cold
Warm
Cold
Warm
Cold
Warm
Cold
Short
3.9E+06
8.6E+07
1.2E+06
1.3E+07
1.2E+05
4.7E+05
3.7E+04
1.3E+05
Intermediate
3.6E+06
4.1E+07
1.3E+06
1.2E+07
1.2E+05
5.2E+05
4.7E+04
4.2E+05
Short-term MOEs
Arsenic risk cumulative density functions and probability density functions (CDFs/PDFs)
were plotted for all exposure scenarios. Short duration (i.e., 1 day to 1 month) risks are shown in
Figure 5-2 for warm climate conditions and in Figure 5-3 for cold climate conditions. Each figure
presents risks from exposure to playsets only (without decks) and playsets and decks (with
decks). Probabilistic short-term MOE distributions and risk levels are presented in Table 5-6 for
warm climates and Table 5-7 for cold climates for arsenic risks with playsets and decks, and
playsets only. MOEs were found to be less than 30 only above the 99th percentile for warm
climates for exposure to playsets only. However, MOEs were greater than 30 with playsets only
under cold climate conditions.
Cr(VI) probabilistic short-term MOE distributions and risk levels (soil ingestion only) for
children with playsets and decks, and playsets only in warm and cold climates are presented in
Tables 5-8 and 5-9, respectively. All MOEs are >100 for all climate scenarios.
5-7
Figure 5-2
MOE of Short-Term ADD for Children Exposed to Arsenic
Dislodgeable Residues and Contaminated Soil from Treated Wood
Playsets and Residential Decks in Warm Climate
(separated by children with and without decks)
Scatterplot (E5 (table 18).sta)
1.0
Without Decks
99% = 61
95% = 173
50% = 1667
mean = 595
With Decks
99% = 53
95% = 107
50% = 771
mean = 383
0.8
0.7
0.6
Without Decks
0.5
With Decks
0.4
0.3
0.2
1.0e6
1.0e5
1.0e4
1.0e3
1.0e2
0.0
1.0e7
hmdeck=0
hmdeck=1
0.1
1.0e1
Cumulative Probability Density
0.9
Note: MOE was not calculated for cases where dose = 0.0.
As a result, the n for deck = 0 was reduced from 755 to 753.
MOE
Histogram (E5 (table 18).sta)
Histogram (E5 (table 18).sta)
y = 746 * 1004.83 * lognorm (x, 7.428197, 1.466526) y = 710 * 1002.237 * lognorm (x, 6.71147, 1.302973)
100%
100%
80%
70%
70%
30%
MOE (Truncated at 10,000)
(N for MOE > 10,000 = 7)
MOE (Truncated at 10,000)
(N for MOE > 10,000 = 22)
5-8
10000
9000
0
10000
9000
8000
7000
6000
5000
4000
3000
2000
0%
1000
10%
0%
8000
20%
10%
7000
20%
40%
6000
30%
50%
4000
40%
60%
3000
50%
2000
60%
1000
Probility Density
80%
0
Probability Density
With Decks
90%
5000
Without Decks
90%
DO NOT CITE, QUOTE, OR DISTRIBUTE
Figure 5-3
MOE of Short-Term ADD for Children Exposed to Arsenic
Dislodgeable Residues and Contaminated Soil from Treated Wood
Playsets and Residential Decks in Cold Climate
(separated by children with and without decks)
Scatterplot (E6 (table 19).sta)
1.0
Without Decks
99% = 108
95% = 304
50% = 3.6x10 3
mean = 1.2x10 3
With Decks
99% = 72
95% = 230
50% = 2023
mean = 745
0.8
0.7
0.6
0.5
0.4
With Decks
Without Decks
0.3
0.2
Note: MOE was not calculated for cases where dose = 0.0.
As a result, n for deck = 0 was reduced from 742 to 709 and
n for deck = 1 was reduced from 720 to 714.
MOE
70%
70%
30%
MOE (Trucated at 100,000)
(N for MOE > 100,000 = 48)
MOE (Truncated at 50,000)
(N for MOE > 50,000 = 22)
5-9
50000
0
1e5
90000
80000
70000
60000
50000
40000
30000
0%
20000
0%
10000
10%
45000
20%
10%
40000
20%
40%
25000
30%
50%
20000
40%
60%
15000
50%
10000
60%
5000
Probability Density
80%
0
With Decks
90%
80%
35000
Without Decks
90%
Probability Density
Histogram (E6 (table 19).sta)
y = 714 * 5047.705 * lognorm (x, 7.58521, 1.43615)
100%
30000
Histogram (E6 (table 19).sta)
y = 708 * 9990.2 * lognorm (x, 8.17327, 1.62748)
100%
1.0e6
1.0e5
1.0e4
1.0e3
1.0e2
0.0
1.0e7
hmdeck=0
hmdeck=1
0.1
1.0e1
Cumulative Probability Density
0.9
Table 5-6. Probabilistic Short-Term MOE Distributions and Risk Levels for Children
Exposed to Arsenic in Warm Climates (Based on Short-term ADDs in Table 18 from the
SHEDS-Wood Document)
Playset Only
Percentile of
Exposure
Average Daily Dose (ADD)
mg/kg/day
MOE
Risk Level
MOE = 30
maximum dose
99
95
90
50
10
5
1
minimum dose
4.1E-03
8.2E-04
2.9E-04
1.8E-04
3.0E-05
3.7E-06
1.9E-06
4.2E-07
0.0E+00
12
61
173
274
1.7E+03
1.3E+04
2.6E+04
1.2E+05
N/A
99.6
1.6E-03
30
Note: Percentiles include cases where dose = 0
Playset and
Deck
Percentile of
Exposure
Average Daily Dose (ADD)
mg/kg/day
MOE
Risk Level
MOE = 30
maximum dose
99
95
90
50
10
5
1
minimum dose
1.5E-03
9.5E-04
4.7E-04
3.1E-04
6.5E-05
9.7E-06
6.6E-06
3.0E-06
8.2E-07
32
53
107
163
771
5.1E+03
7.5E+03
1.7E+04
6.1E+04
>99.9
N/A
30
Note: Shaded area indicates all the percentiles of the population that meet the risk level set by the Agency.
5-10
Table 5-7. Probabilistic Short-term MOE Distributions and Risk Levels for Children
Exposed to Arsenic in Cold Climates (Based on Short-Term ADDs in
Table 19 from the SHEDS-Wood Document)
Playset Only
Percentile of
Exposure
Average Daily Dose (ADD)
mg/kg/day
MOE
Risk Level
MOE = 30
maximum dose
99
95
90
50
10
5
1
minimum dose
1.3E-03
4.6E-04
1.6E-04
1.0E-04
1.4E-05
9.5E-07
1.0E-07
0.0E+00
0.0E+00
38
108
304
497
3.6E+03
5.3E+04
5.0E+05
N/A
N/A
>99.9
N/A
30
Note: Percentiles include cases where dose = 0
Playset and
Deck
Percentile of
Exposure
Average Daily Dose (ADD)
mg/kg/day
MOE
Risk Level
MOE = 30
maximum dose
99
95
90
50
10
5
1
minimum dose
2.3E-03
7.0E-04
2.2E-04
1.4E-04
2.5E-05
4.0E-06
2.1E-06
1.2E-07
0.0E+00
21
72
230
351
2.0E+03
1.2E+04
2.4E+04
4.2E+05
N/A
99.6
1.5E-03
30
Note: Percentiles include cases where dose = 0
Note: Shaded area indicates all the percentiles of the population that meet the risk level set by the Agency.
5-11
Table 5-8. Probabilistic Short-Term MOE Distributions and Risk Levels for Children
Exposed to Chromium (VI) in Warm Climate
(Soil Ingestion Only)
Playset Only
Percentile of
Exposure
Cr VI Average Daily Dose
(ADD) mg/kg/day
Cr VI MOE
Risk Level
MOE = 100
maximum dose
99
95
90
50
10
5
1
minimum dose
>99.9
3.4E-05
1.5E-05
4.3E-06
1.9E-06
1.8E-07
1.5E-08
5.6E-09
7.8E-10
0.0E+00
N/A
1.5E+04
3.3E+04
1.2E+05
2.6E+05
2.8E+06
3.3E+07
8.9E+07
6.4E+08
N/A
100
Note: Percentiles include cases where dose = 0
Playset and
Deck
Percentile of
Exposure
Cr VI Average Daily Dose
(ADD) mg/kg/day
Cr VI MOE
Risk Level
MOE = 100
maximum dose
99
95
90
50
10
5
1
minimum dose
>99.9
4.2E-05
1.3E-05
3.9E-06
2.1E-06
2.5E-07
2.0E-08
1.2E-08
2.2E-09
8.1E-10
N/A
1.2E+04
3.8E+04
1.3E+05
2.4E+05
2.0E+06
2.4E+07
4.3E+07
2.3E+08
6.2E+08
100
Note: Shaded area indicates all the percentiles of the population that meet the risk level set by the Agency.
5-12
Table 5-9. Probabilistic Short-Term MOE Distributions and Risk Levels for Children
Exposed to Chromium (VI) in Cold Climate
(Soil Ingestion Only)
Playset Only
Percentile of
Exposure
Cr VI Average Daily Dose
(ADD) mg/kg/day
Cr VI MOE
1.9E-05
3.0E-06
6.9E-07
3.0E-07
1.5E-08
3.8E-10
6.4E-11
0.0E+00
0.0E+00
N/A
2.7E+04
1.6E+05
7.2E+05
1.7E+06
3.4E+07
1.3E+09
7.8E+09
N/A
N/A
100
Risk Level
MOE = 100
maximum dose
99
95
90
50
10
5
1
minimum dose
>99.9
Note: Percentiles include cases where dose = 0
Playset and
Deck
Percentile of
Exposure
Cr VI Average Daily Dose
(ADD) mg/kg/day
Cr VI MOE
1.5E-05
3.7E-06
1.0E-06
5.2E-07
2.9E-08
2.0E-09
8.0E-10
0.0E+00
0.0E+00
N/A
3.4E+04
1.3E+05
4.9E+05
9.6E+05
1.7E+07
2.5E+08
6.2E+08
N/A
N/A
100
Risk Level
MOE = 100
maximum dose
99
95
90
50
10
5
1
minimum dose
>99.9
Note: Percentiles include cases where dose = 0
Note: Shaded area indicates all the percentiles of the population that meet the risk level set by the Agency.
5-13
Arsenic PDFs/CDFs and risk levels are not presented for pica children. However, shortterm MOEs for arsenic for pica children and playsets only in warm climates are presented in
Table 5-10. For all scenarios evaluated, the arsenic short-term MOEs were greater than 30 at the
95th percentile. For playset only exposure, the MOE was less than 30 near the 99th percentile. For
deck and playset exposure, the MOE was slightly greater than 30 at the 99th percentile. This
reversal of deck and playset and playset only risks was due to the exposure model’s instability at
this extreme dose levels. The SHEDS-Wood assessment did not calculate short-term MOEs for
chromium for pica children. See Appendix B for additional short-term MOEs.
Intermediate-term MOEs
Arsenic risk PDFs/CDFs were plotted for all exposure scenarios. Intermediate duration
(i.e., 1 to 6 months) risks are shown in Figure 5-4 for warm climate conditions and Figure 5-5 for
cold climate conditions. Each figure presents risks from exposure to playsets only, and playsets
and decks. Probabilistic intermediate-term MOE distributions and risk levels are presented in
Table 5-11 for warm climates and Table 5-12 for cold climates for arsenic risks with playsets and
decks, and playsets only. MOEs were shown to be less than 30 at the 99th percentile for both
warm and cold climate conditions for exposure to playsets and decks and playsets only.
Chromium intermediate-term MOEs and risk levels (soil ingestion only) for children with
playsets and decks, and playsets only at warm and cold climates are presented in Tables 5-13 and
5-14, respectively. All MOEs were found to be greater than 100 for exposure to playsets and
decks, and playsets only for both climate scenarios.
5-14
Table 5-10. Arsenic Noncancer Short-Term MOEs for
Pica Children in Warm Climate
(Based on Short-Term ADDs from Table 33 in the SHEDS-Wood Document)
Arsenic (guidance MOE = 30)
LOAEL of 0.05 mg/kg/day
Source of Exposure
Mean
Median
95%ile
99%ile
Playset Only
219
503
65
23
Playset and Deck
163
339
49
31
5-15
Figure 5-4
MOE of Intermediate-Term ADD for Children Exposed to Arsenic
Dislodgeable Residues and Contaminated Soil from Treated Wood
Playsets and Residential Decks in Warm Climate
(separated by children with and without decks)
Scatterplot (E3 (table 16).sta)
1.0
W ithout Decks
99% = 116
95% = 216
50% = 1812
m ean = 849
W ith Decks
99% = 52
95% = 111
50% = 739
m ean = 393
0.8
0.7
0.6
Without Decks
0.5
0.4
With Decks
0.3
0.2
1.0e6
1.0e5
1.0e4
1.0e3
0.0
1.0e2
0.1
1.0e7
hmdeck=0
hmdeck=1
1.0e1
Cumulative Probability Density
0.9
MOE
Histogram (E3 (table 16).sta)
y = 752 * 1013.43 * lognorm (x, 6.666364, 1.210376)
100%
80%
70%
70%
30%
0
40000
36000
32000
28000
24000
20000
16000
12000
0%
8000
0%
4000
10%
MOE (truncated at 40,000)
(N for MOE > 40,000 = 30)
MOE (truncated at 10,000)
(N for MOE > 10,000 = 15)
5-16
10000
20%
10%
9000
20%
40%
5000
30%
4000
40%
50%
3000
50%
60%
2000
60%
1000
Probability Density
80%
0
Probability Density
With Decks
90%
8000
Without Decks
90%
7000
100%
6000
Histogram (E3 (table 16).sta)
y = 715 * 4011.28 * lognorm (x, 7.67602, 1.52912)
DO NOT CITE, QUOTE, OR DISTRIBUTE
Figure 5-5
MOE of Intermediate-Term ADD for Children Exposed to Arsenic
Dislodgeable Residues and Contaminated Soil from Treated Wood
Playsets and Residential Decks in Cold Climate
(separated by children with and without decks)
Scatterplot (E4 (table 17).sta)
1.0
Without Decks
99% = 128
95% =415
50% = 4.6x10 3
mean = 1.3x103
With Decks
99% = 84
95% = 211
50% = 1.6x10 3
mean = 7.2x102
0.8
0.7
0.6
Without Decks
0.5
0.4
With Decks
0.3
0.2
1.0e6
1.0e5
1.0e4
1.0e3
1.0e2
0.0
1.0e7
hmdeck=0
hmdeck=1
0.1
1.0e1
Cumulative Probability Density
0.9
Note: MOE was not calculated for cases where dose = 0.0.
As a result, the n for deck = 0 was reduced from 721 to 718.
MOE
Histogram (E4 (table 17).sta)
Histogram (E4 (table 17).sta)
y = 718 * 4993.957 * lognorm (x, 8.484687, 1.64317) y = 742 * 1006.23 * lognorm (x, 7.367597, 1.255487)
100%
100%
70%
30%
MOE (truncated at 50,000)
(N for MOE > 50,000 = 56)
MOE (truncated at 10,000)
(N for MOE > 10,000 = 54)
5-17
10000
9000
0
50000
45000
40000
35000
30000
25000
20000
15000
10000
0%
5000
10%
0%
8000
20%
10%
7000
20%
40%
6000
30%
50%
4000
40%
60%
3000
50%
2000
60%
1000
Probability Density
80%
70%
0
Probability Density
With Decks
90%
80%
5000
Without Decks
90%
Table 5-11. Probabilistic Intermediate-Term MOE Distributions and Risk Levels for
Children Exposed to Arsenic in Warm Climates
(Based on the ADDs in Table 16 from the SHEDS-Wood Document)
Playset Only
Percentile of
Exposure
Average Daily Dose (ADD)
mg/kg/day
MOE
Risk Level
MOE = 30
maximum dose
99
95
90
50
10
5
1
minimum dose
8.6E-04
4.3E-04
2.3E-04
1.5E-04
2.8E-05
3.2E-06
1.7E-06
3.9E-07
4.9E-08
>99.9
58
116
216
339
1.8E+03
1.6E+04
3.0E+04
1.3E+05
1.0E+06
30
Playset and
Deck
Percentile of
Exposure
Average Daily Dose (ADD)
mg/kg/day
MOE
Risk Level
MOE = 30
maximum dose
99
95
90
50
10
5
1
minimum dose
2.0E-03
9.6E-04
4.5E-04
3.1E-04
6.8E-05
1.4E-05
8.8E-06
3.7E-06
7.0E-07
25
52
111
159
740
3.6E+03
5.7E+03
1.4E+04
7.1E+04
99.6
1.4E-03
30
Note: Shaded area indicates all the percentiles of the population that meet the risk level set by the Agency.
5-18
Table 5-12. Probabilistic Intermediate-Term MOE Distributions and Risk Levels for
Children Exposed to Arsenic in Cold Climates
(Based on ADDs in Table 17 from the SHEDS-Wood Document)
Playset Only
Percentile of
Exposure
Average Daily Dose (ADD)
mg/kg/day
MOE
Risk Level
MOE = 30
maximum dose
99
95
90
50
10
5
1
minimum dose
3.1E-03
3.9E-04
1.2E-04
7.5E-05
1.1E-05
1.3E-06
5.7E-07
9.8E-08
0.0E+00
16
128
415
664
4.6E+03
3.8E+04
8.8E+04
5.1E+05
N/A
99.7
1.4E-03
30
Note: Percentiles include cases where dose = 0
Playset and
Deck
Percentile of
Exposure
Average Daily Dose (ADD)
mg/kg/day
MOE
Risk Level
MOE = 30
maximum dose
99
95
90
50
10
5
1
minimum dose
2.4E-03
5.9E-04
2.4E-04
1.5E-04
3.1E-05
6.7E-06
3.9E-06
1.5E-06
7.2E-07
21
84
211
325
1.6E+03
7.4E+03
1.3E+04
3.4E+04
6.9E+04
99.7
1.3E-03
30
Note: Shaded area indicates all the percentiles of the population that meet the risk level set by the Agency.
5-19
Table 5-13. Probabilistic Intermediate-Term MOE Distributions and Risk Levels for
Children Exposed to Chromium (VI) in Warm Climate
(Soil Ingestion Only)
Playset Only
Percentile of
Exposure
Cr VI Average Daily Dose
(ADD) mg/kg/day
Cr VI MOE
3.6E-05
1.6E-05
3.5E-06
1.6E-06
1.6E-07
1.1E-08
5.0E-09
6.6E-10
1.0E-11
N/A
1.4E+04
3.0E+04
1.4E+05
3.0E+05
3.1E+06
4.6E+07
9.9E+07
7.6E+08
5.0E+10
100
Cr VI Average Daily Dose
(ADD) mg/kg/day
Cr VI MOE
6.6E-05
1.0E-05
3.5E-06
1.8E-06
2.3E-07
2.2E-08
9.4E-09
3.4E-09
6.1E-10
N/A
7.5E+03
4.9E+04
1.4E+05
2.8E+05
2.2E+06
2.2E+07
5.3E+07
1.5E+08
8.2E+08
100
Risk Level
MOE = 100
maximum dose
99
95
90
50
10
5
1
minimum dose
>99.9
Playset and
Deck
Percentile of
Exposure
Risk Level
MOE = 100
maximum dose
99
95
90
50
10
5
1
minimum dose
>99.9
Note: Shaded area indicates all the percentiles of the population that meet the risk level set by the Agency.
5-20
Table 5-14. Probabilistic Intermediate-Term MOE Distributions and Risk Levels for
Children Exposed to Chromium (VI) in Cold Climate
(Soil Ingestion Only)
Playset Only
Percentile of
Exposure
Cr VI Average Daily Dose
(ADD) mg/kg/day
Cr VI MOE
8.4E-06
1.8E-06
6.0E-07
2.7E-07
1.4E-08
6.5E-10
3.4E-10
3.5E-11
0.0E+00
N/A
5.9E+04
2.8E+05
8.3E+05
1.9E+06
3.5E+07
7.7E+08
1.5E+09
1.4E+10
N/A
100
Risk Level
MOE = 100
maximum dose
99
95
90
50
10
5
1
minimum dose
>99.9
Note: Percentiles include cases where dose = 0
Playset and
Deck
Percentile of
Exposure
Cr VI Average Daily Dose
(ADD) mg/kg/day
Cr VI MOE
1.2E-05
3.4E-06
8.9E-07
4.3E-07
3.5E-08
2.7E-09
1.3E-09
4.8E-10
1.4E-10
N/A
4.3E+04
1.5E+05
5.6E+05
1.2E+06
1.4E+07
1.9E+08
3.7E+08
1.0E+09
3.6E+09
100
Risk Level
MOE = 100
maximum dose
99
95
90
50
10
5
1
minimum dose
>99.9
Note: Shaded area indicates all the percentiles of the population that meet the risk level set by the Agency.
5-21
5.2.2 Carcinogenic Effects
For carcinogens, risks were estimated as the probability of increased cancer incidence or
excess lifetime cancer risk. The carcinogenic slope factor or Q1* represents the 95 percent upper
confidence limit (UCL) of the probability of response per unit intake of a chemical over a lifetime,
and converts estimated intakes directly to incremental risk (U.S. EPA, 1990). Cancer risk was
computed as follows:
Risk = LADD x Q1*
Where:
LADD =
Q1*
=
Lifetime Average Daily Dose (mg/kg/day)
Carcinogenic slope factor [1/(mg/kg/-day)]
Doses (i.e., LADDs) corresponding to all risks calculated here are presented in Zartarian et al.
(2003). The lifetime risk was based on a 6 year duration of exposure (ages 1-6 years) and
averaged over a lifetime of 75 years.
Cancer risk results are presented in this section from four different perspectives. First,
risks are presented in the same manner as the noncancer effects; namely, the four different
exposure points (i.e., mean, median, 95th percentile, and 99th percentile) are presented. Second,
risks are shown in cumulative probability density and probability density plots. Third, percentiles
from the cumulative distribution that correspond to the three levels of EPA’s risk range (10 -6,
10-5, and 10-4) are presented. And fourth, total risk is shown for two broad sources of exposure:
soils and residues. The risk data for exposure to residues and soil in warm and cold climates are
shown in line plots (Figures 5-6 and 5-7) for the different exposure scenarios (i.e., playset only
and playset and deck) .
Table 5-15 summarizes the arsenic cancer risks for children who contact CCA-treated
playsets and decks in warm and cold climates at the three exposure points of interest. Warm
climate exposures were greater than cold climate exposures. Thus, cancer risks were
correspondingly greater. Exposure at the mean and median were in the range 10 -6 to10 -5. This
range was exceeded with exposure to decks and playsets in warm climates at approximately the
95th percentile (1.4 x10-4). At the 99 th percentile, the 10-4 risk level was exceeded for playsets and
decks exposure for cold climate conditions.
5-22
Figure 5-6
Cancer Risk (Lifetime Term) for Children Exposed to Arsenic
Dislodgeable Residues and Contaminated Soil from Treated Wood
Playsets and Residential Decks in Warm Climate
(separated by children with and without decks)
Scatterplot (E1 (table 14).sta)
1.0
Without Decks
99% = 2.4x10-4
95% = 8.3x10-5
50% = 1.1x10-5
mean = 2.3x10-5
With Decks
99% = 3.1x10-4
95% = 1.4x10-4
50% = 2.3x10-5
mean = 4.2x10-5
0.8
0.7
0.6
0.5
0.4
0.3
Without Decks
With Decks
0.2
1.0e-4
1.0e-5
1.0e-6
0.0
1.0e-7
0.1
1.0e-3
deck=0
deck=1
1.0e-8
Cumulative Probability Density
0.9
Cancer Risk
Histogram (E1 (table 14).sta)
Histogram (E1 (table 14).sta)
y = 728 * 0.000012 * lognorm (x, -11.42044, 1.2201) y = 738 * 0.00001 * lognorm (x, -10.689, 1.098477)
100%
100%
Without Decks
90%
80%
70%
70%
Probability Density
80%
60%
50%
40%
30%
20%
With Decks
60%
50%
40%
30%
20%
10%
0%
0%
0
1e-5
2e-5
3e-5
4e-5
5e-5
6e-5
7e-5
8e-5
9e-5
1e-4
1.1e-4
1.2e-4
1.3e-4
1.4e-4
1.5e-4
10%
0
1e-5
2e-5
3e-5
4e-5
5e-5
6e-5
7e-5
8e-5
9e-5
1e-4
1.1e-4
1.2e-4
1.3e-4
1.4e-4
1.5e-4
Probability Density
90%
Cancer Risk (truncated at 1.5e-4)
(N for risks > 1.5e-4 = 16)
Cancer Risk (truncated at 1.5e-4)
(N for risks > 1.5e-4 = 31)
5-23
Figure 5-7
Cancer Risk (Lifetime Term) for Children Exposed to Arsenic
Dislodgeable Residues and Contaminated Soil from Treated Wood
Playsets and Residential Decks in Cold Climate
(separated by children with and without decks)
Scatterplot (E2 (table 15).sta)
1.0
Without Decks
99% = 8.9x10-5
95% = 4.5x10-5
50% = 5.4x10-6
mean = 1.2x10-5
With Decks
99% = 1.6x10-4
95% = 7.8x10-5
50% = 1.1x10-5
mean = 2.2x10-5
Cumulative Probability Density
0.9
0.8
0.7
0.6
0.5
0.4
0.3
Without Decks
With Decks
0.2
hmdeck=0
hmdeck=1
1.0e-3
1.0e-4
1.0e-5
1.0e-6
1.0e-7
0.0
1.0e-8
0.1
Cancer Risk
100%
80%
70%
70%
30%
Cancer Risk (Truncated at 1e-4)
(N for risks > 1e-4 = 6)
Cancer Risk (truncated at 1e-4)
(N for risks > 1e-4 = 22)
5-24
1e-4
0
1e-4
9e-5
8e-5
7e-5
6e-5
5e-5
4e-5
3e-5
2e-5
0%
1e-5
10%
0%
9e-5
20%
10%
8e-5
20%
40%
7e-5
30%
50%
4e-5
40%
60%
3e-5
50%
2e-5
60%
1e-5
Probability Density
80%
0
With Decks
90%
6e-5
Without Decks
90%
Probability Density
Histogram (E2 (table 15).sta)
y = 718 * 0.000005 * lognorm (x, -11.40915, 1.195903)
5e-5
Histogram (E2 (table 15).sta)
y = 744 * 0.000005 * lognorm (x, -12.13274, 1.28142)
100%
Table 5-15. Arsenic Cancer Risks
Arsenic (Q1*= 3.67 (mg/kg/day)-1)
Mean
Scenario
Median
95%ile
99%ile
Warm
Cold
Warm
Cold
Warm
Cold
Warm
Cold
Playset and
Deck
4.2E-05
2.2E-05
2.3E-05
1.1E-05
1.4E-04
7.8E-05
3.1E-04
1.6E-04
Playset Only
2.3E-05
1.2E-05
1.1E-05
5.4E-06
8.3E-05
4.5E-05
2.4E-04
8.9E-05
The cumulative probability density and probability density plots for warm climates and
cold climates are presented in Figures 5-6 and 5-7, respectively. Risks due to both types of
exposure (i.e., playsets only, and playsets and decks) are shown on the cumulative probability
density plot. Figure 5-6 shows that risks for warm climate conditions are less than the EPA’s risk
level of 10-6 only at extremely low cumulative probabilities (e.g., less than the 5th percentile for
both exposure to playsets alone as well as with deck exposure). For cold climate conditions
(Figure 5-7), the same pattern is evident. However, the cumulative probability curve shifted to
the left slightly, as risks were lower due to lower levels of exposure.
Tables 5-16 and 5-17 present cumulative percentiles at the three specified risk levels for
warm and cold climates playsets and decks, and playsets only. For the warm climate, risks were
equal to 10 -6 at the 3 rd percentile for exposure to playsets only and less than the 1st percentile for
exposure to playsets and decks. In cold climates, these percentiles are the 9th and 2nd,
respectively. Risks of 10-4 were exceeded at cumulative percentiles that range from the 90th
percentile for exposure to playsets and decks in a warm climate to the 99th percentile for playsets
only in a cold climate.
The last analysis of these data focused on evaluating the differing contributions to total
risk from soil and disloadgeable residues. This was a screening level analysis using the summary
statistics for each route of exposure. The estimated risks are considered approximations because
inaccuracies occur when exposures are summed across routes at the quartile level. This is due to
the way the Monte Carlo simulations were conducted and the outputs summarized. Errors are
expected to be greatest at the lowest percentiles, minimal at the median, and then increase in the
upper percentiles. Inaccuracy at the upper percentiles ranges from 10% to approximately greater
than 20% depending on the exposure scenario. Appendix B shows how risks from ingestion and
dermal absorption were summed across decks and playsets, and for residue and soil exposures.
Plots presented are for warm climate, as this scenario had the highest risk.
5-25
Table 5-16. Probabilistic Cancer Risk Distributions and Risk Levels for Children Exposed to
Arsenic in Warm Climates
(Based on LADDs in Table 14 from the SHEDS-Wood Document)
Playset Only
Percentile of
Exposure
Lifetime Average Daily Dose Cancer Risk
(LADD) mg/kg/day
Risk Level
A = 1.0E-6
maximum
99
95
90
50
10
5
1
minimum
1.3E-04
6.5E-05
2.3E-05
1.3E-05
3.0E-06
7.2E-07
4.6E-07
1.3E-07
2.9E-08
4.9E-04
2.4E-04
8.3E-05
4.7E-05
1.1E-05
2.6E-06
1.7E-06
4.8E-07
1.0E-07
96.6
46.7
3.0
2.7E-05
2.7E-06
2.7E-07
1.0E-04
1.0E-05
1.0E-06
B = 1.0E-5
C = 1.0E-4
Playset and
Deck
Percentile of
Exposure
Lifetime Average Daily Dose Cancer Risk
(LADD) mg/kg/day
Risk Level
A = 1.0E-6
maximum
99
95
90
50
10
5
1
minimum
1.7E-04
8.4E-05
3.9E-05
2.8E-05
6.1E-06
1.5E-06
1.0E-06
5.1E-07
2.5E-07
6.1E-04
3.1E-04
1.4E-04
1.0E-04
2.3E-05
5.6E-06
3.7E-06
1.9E-06
9.1E-07
89.8
22.9
0.3
2.7E-05
2.7E-06
2.5E-07
1.0E-04
1.0E-05
1.0E-06
B = 1.0E-5
Note: Shaded area indicates all the percentiles of the population that meet the risk level set by the Agency.
5-26
C = 1.0E-4
Table 5-17. Probabilistic Cancer Risk Distributions and Risk Levels for Children Exposed to
Arsenic in Cold Climates
(Based on LADDs in Table 15 from the SHEDS-Wood Document)
Playset Only
Percentile of
Exposure
Lifetime Average Daily Dose Cancer Risk
(LADD) mg/kg/day
Risk Level
A = 1.0E-6
maximum
99
95
90
50
10
5
1
minimum
5.4E-05
2.4E-05
1.2E-05
8.0E-06
1.5E-06
2.9E-07
1.7E-07
8.0E-08
5.1E-09
2.0E-04
8.9E-05
4.5E-05
2.9E-05
5.4E-06
1.1E-06
6.2E-07
2.9E-07
1.9E-08
99.2
69.1
9.0
2.6E-05
2.7E-06
2.7E-07
1.0E-04
1.0E-05
1.0E-06
B = 1.0E-5
C = 1.0E-4
Playset and
Deck
Percentile of
Exposure
Lifetime Average Daily Dose Cancer Risk
(LADD) mg/kg/day
Risk Level
A = 1.0E-6
maximum
99
95
90
50
10
5
1
minimum
1.0E-04
4.4E-05
2.1E-05
1.4E-05
2.9E-06
6.2E-07
4.1E-07
2.0E-07
7.5E-08
3.8E-04
1.6E-04
7.8E-05
5.0E-05
1.1E-05
2.3E-06
1.5E-06
7.4E-07
2.7E-07
96.8
48.5
2.4
2.7E-05
2.7E-06
2.7E-07
1.0E-04
1.0E-05
1.0E-06
B = 1.0E-5
Note: Shaded area indicates all the percentiles of the population that meet the risk level set by the Agency.
5-27
C = 1.0E-4
Figure 5-8 presents an approximate cumulative probability density plot for risks from soil
and residue exposure. The lines in this plot are not true cumulative probabilities because risks
were only calculated at the quartiles, as shown by the large dots; the lines merely connect the
dots. Two observations are clearly shown in this plot. First, residue exposures have greater risk
than soil exposure; and second, the difference between playset only versus playset and deck
residue risk is less than the difference between residue and soil risk. At the 50th percentile,
residue risk for playset and deck exposure is slightly greater than 10-5 and approximately 10-4 at
the 95th percentile. The 10-4 risk level is exceeded for playset only exposure approaching the 99th
percentile. Figure 5-9 is a bar chart of the risks from three different levels of exposure: 50th, 95th
and 99th percentiles. At each level, there are four bars: soil and residue exposure for playsets
alone and soil and residue exposure for both decks and playsets. Residue risk for playset only
exposure exceeds the soil risk by a factor of approximately 6-7 at the 50th percentile and 95th
percentiles, and by a factor of approximately 10 at the 99th percentile. For playset and deck
exposure, residue risk is approximately 10 times greater that the soil risk at all three cumulative
percentiles. Soil exposure risk exceeds 10-5 at the 95 th percentile for both categories of exposure.
Residue risk for playsets only is slightly less than 10-4 and slightly greater than 10-4 for playsets
and decks at the 95th percentile.
5.3
Risk Reduction Assuming 0.01% Dermal Absorption Rate
SHEDS-Wood used 2-3% as the arsenic dermal absorption rate (recommended by the
FIFRA SAP) based on Wester et al. (1993). Zartarian et al.(2003) acknowledged that this value
may be closer to 1% due to physical removal processes prior to absorption through the skin
surface. However based on a dermal absorption study for monkeys reported by Wester et al.
(2003), OPP also modeled exposure in SHEDS-Wood based on a 0.01% dermal absorption,
which is considerably lower than previously reported by Wester et al. (1993). The 0.01% dermal
absorption from the preliminary results of Wester et al. (2003) was based on urinary arsenic data
following application of arsenic in CCA residue that had been weathered by the environment.
Values reported for soluble arsenic were much higher, 3.6, 0.55, and 4.1 percent. Calculating
risks for a lower dermal absorption value provided an indication of the sensitivity of the model to
this parameter as well as risks under a fundamentally different assumption.
For this evaluation, risks were calculated for both warm and cold climate conditions.
Table 5-18 presents the mean, median, 95th, and 99th percentiles for the two exposure scenarios of
playsets and decks, and playsets only. At the median, the lowest risk level was 4.2 x 10-6 for
playset only exposure under cold climate conditions; the highest was 1.7 x 10-5 for playset and
deck exposure under warm climate conditions. At the 95 th percentile, all exposure scenarios
exceeded the 10-5 risk level. Tables 5-19 and 5-20 present the probabilistic cancer risk
distributions and risk levels for exposure to arsenic in warm and cold climates, respectively, based
on the assumed dermal absorption rate of 0.01%.
5-28
Figure 5-8 Comparison of Total Arsenic Risks from Playsets and Decks for Warm Climate
Baseline
Cumulative Probability Density
100
90
Soil risk - playset only
80
Soil risk - decks & playsets
70
Residue risk -playset only
60
Residue risk - decks & playsets
50
40
30
20
10
0
1.0E-09
1.0E-08
1.0E-07
1.0E-06
Carcinogenic Risk
5-29
1.0E-05
1.0E-04
1.0E-03
Figure 5-9 Comparison of Residue and Soil Total Arsenic Risks for Warm Climate
Baseline
1.0E-03
Residue risk -playset only
Soil risk - playset only
Residue risk - decks & playsets
Soil risk - decks & playsets
Cancer Risk
1.0E-04
1.0E-05
1.0E-06
50%ile
95%tile
5-30
99%tile
Table 5-18. Arsenic Cancer Risk Assuming 0.01% Dermal Absorption
Arsenic (Q1*= 3.67 (mg/kg/day)-1)
Scenario
Mean
Median
95%ile
99%ile
Warm
Cold
Warm
Cold
Warm
Cold
Warm
Cold
Playset and
Deck
2.9E-05
2.0E-05
1.7E-05
9.8E-06
9.8E-05
7.7E-05
2.3E-04
1.6E-04
Playset Only
1.5E-05
1.1E-05
7.3E-06
4.2E-06
4.4E-05
3.8E-05
1.2E-04
9.9E-05
5-31
Table 5-19. Probabilistic Cancer Risk Distributions and Risk Levels for Children Exposed to
Arsenic in Warm Climates (Dermal Residue Absorption Rate = 0.01%)
(Based on LADDs in Table 35 from the SHEDS-Wood Document)
Playset Only
Percentile of
Exposure
Lifetime Average Daily Dose Cancer Risk
(LADD) mg/kg/day
Risk Level
A = 1.0E-6
maximum
99
95
90
50
10
5
1
minimum
1.9E-04
3.3E-05
1.2E-05
7.8E-06
2.0E-06
4.3E-07
2.8E-07
6.1E-08
3.4E-09
7.1E-04
1.2E-04
4.4E-05
2.9E-05
7.3E-06
1.6E-06
1.0E-06
2.2E-07
1.2E-08
98.2
61.3
4.7
2.4E-05
2.7E-06
2.6E-07
1.0E-04
1.0E-05
1.0E-06
B = 1.0E-5
C = 1.0E-4
Playset and
Deck
Percentile of
Exposure
Lifetime Average Daily Dose Cancer Risk
(LADD) mg/kg/day
Risk Level
A = 1.0E-6
maximum
99
95
90
50
10
5
1
minimum
2.3E-04
6.4E-05
2.7E-05
1.6E-05
4.5E-06
9.1E-07
6.3E-07
2.8E-07
1.1E-07
8.6E-04
2.3E-04
9.8E-05
6.0E-05
1.7E-05
3.3E-06
2.3E-06
1.0E-06
4.1E-07
95.1
33.8
0.9
2.7E-05
2.7E-06
2.5E-07
1.0E-04
1.0E-05
1.0E-06
B = 1.0E-5
Note: Shaded area indicates all the percentiles of the population that meet the risk level set by the Agency.
5-32
C = 1.0E-4
Table 5-20. Probabilistic Cancer Risk Distributions and Risk Levels for Children Exposed to
Arsenic in Cold Climate (Dermal Residue Absorption Rate = 0.01%)
(Based on LADDs in Table 36 From SHEDS-Wood Document)
Playset Only
Percentile of
Exposure
Lifetime Average Daily Dose Cancer Risk
(LADD) mg/kg/day
Risk Level
A = 1.0E-6
maximum
99
95
90
50
10
5
1
minimum
1.2E-04
2.7E-05
1.0E-05
6.2E-06
1.1E-06
2.3E-07
1.5E-07
5.4E-08
1.2E-08
4.3E-04
9.9E-05
3.8E-05
2.3E-05
4.2E-06
8.4E-07
5.6E-07
2.0E-07
4.4E-08
99.1
73.1
12.6
2.7E-05
2.7E-06
2.7E-07
1.0E-04
1.0E-05
1.0E-06
B = 1.0E-5
C = 1.0E-4
Playset and
Deck
Percentile of
Exposure
Lifetime Average Daily Dose Cancer Risk
(LADD) mg/kg/day
Risk Level
A = 1.0E-6
maximum
99
95
90
50
10
5
1
minimum
8.2E-05
4.3E-05
2.1E-05
1.2E-05
2.7E-06
6.0E-07
3.4E-07
1.6E-07
4.7E-08
3.0E-04
1.6E-04
7.7E-05
4.4E-05
9.8E-06
2.2E-06
1.3E-06
6.0E-07
1.7E-07
96.6
50.5
3.5
2.7E-05
2.7E-06
2.7E-07
1.0E-04
1.0E-05
1.0E-06
B = 1.0E-5
Note: Shaded area indicates all the percentiles of the population that meet the risk level set by the Agency.
5-33
C = 1.0E-4
For comparison of these risk levels to the baseline risks, Table 5-21 presents the median
and 95th percentile risks for the baseline (2 to 4%) and Wester et al. (2003)(0.01%) dermal
absorption values under warm climate conditions. Differences in risk levels between the two
dermal assumptions for exposure to playsets and decks ranged from 26% at the median to 30% at
the 95th percentile. For playsets only, the range was greater; 34% to 47%. Changing the dermal
absorption factor by approximately two orders of magnitude had a much smaller effect on total
risk because the dominant route of exposure was ingestion, not dermal uptake.
Table 5-21. Comparison of Arsenic Risks Between Baseline and 0.01% Dermal Absorption
Warm Climate
Dermal
Absorption
Assumption
Median
95th%ile
Median
95th%ile
Baseline (2-4%)
2.3E-05
1.4E-04
1.1E-05
8.3E-05
Wester et al.
(2003) (0.01%)
1.7E-05
9.8E-05
7.3E-06
4.4E-05
26%
30%
34%
47%
Difference
Playset and Deck
Playset Only
Figure 5-10 presents the PDF and CDF distributions of the risks under warm climate
conditions based on the assumed 0.01% dermal absorption. (The corresponding plots for cold
climate conditions are in Figure 5-11.) Looking at the warm climate, the cumulative percentile at
the lower end of EPA’s risk level, 10-6, is approximately the 5th for playsets only exposure and less
than the 1 st for playsets and decks exposure (Table 5-19). For baseline warm conditions, the
percentiles at this risk level are the 3rd and less than the 1st for playsets only, and playsets and
decks exposure, respectively (Table 5-16). For dermal absorption at 0.01%, the upper end of the
range, 10-4, is exceeded above the 98th percentile for playsets only and the 95th percentile for
playsets and deck exposure (Table 5-19). Reducing the dermal absorption factor to 0.01% shifts
the cumulative percentiles a small amount toward lower risks over baseline conditions.
5-34
Figure 5-10
Cancer Risk from Lifetime-Term LADD for Children Exposed to Arsenic
Dislodgeable Residues and Contaminated Soil from Treated Wood
Playsets and Residential Decks in Warm Climate
(Dermal Residue Absorption Rate = 0.01%)
Scatterplot (E7 (table 25.sta))
1.0
Without Decks
99% = 1.2x10-4
95% = 4.4x10-5
50% = 7.3x10-6
mean = 1.5x10-5
With Decks
99% = 2.3x10-4
95% = 9.8x10-5
50% = 1.7x10-5
mean = 2.9x10-5
0.8
0.7
0.6
0.5
0.4
0.3
Without Decks
With Decks
1.0e-4
1.0e-5
1.0e-6
0.0
1.0e-7
0.1
1.0e-3
hmdeck=0
hmdeck=1
0.2
1.0e-8
Cumulative Probability Density
0.9
Cancer Risk
80%
70%
70%
30%
Cancer Risk (Truncated at 1e-4)
(N for Risk > 1e-4 = 16)
Cancer Risk (Truncated at 1e-4)
(N for Risk > 1e-4 = 36)
5-35
1e-4
0
1e-4
9e-5
8e-5
7e-5
6e-5
5e-5
4e-5
3e-5
0%
2e-5
10%
0%
1e-5
10%
9e-5
20%
8e-5
20%
40%
7e-5
30%
50%
4e-5
40%
60%
3e-5
50%
2e-5
60%
1e-5
Probability Density
80%
0
With Decks
90%
6e-5
Without Decks
90%
Probability Density
Histogram ((E7 (table 24).sta)
y = 740 * 0.00001 * lognorm (x, -11.08683, 1.13462)
100%
5e-5
Histogram (E7 (table 24).sta)
y = 731 * 0.00001 * lognorm (x, -11.8661, 1.23215)
100%
Figure 5-11
Cancer Risk from Lifetime-Term LADD for Children Exposed to Arsenic
Dislodgeable Residues and Contaminated Soil from Treated Wood
Playsets and Residential Decks in Cold Climate
(Dermal Residue Absorption Rate = 0.01%)
Scatterplot (E8 (table 36).sta)
1.0
Without Decks
99% = 9.9x10-5
95% = 3.8x10-5
50% = 4.2x10-6
mean = 1.1x10-5
With Decks
99% = 1.6x10-4
95% = 7.7x10-5
50% = 9.8x10-6
mean = 2.0x10-5
0.8
0.7
0.6
0.5
0.4
0.3
Without Decks
With Decks
0.2
hmdeck=0
hmdeck=1
1.0e-3
1.0e-4
1.0e-5
1.0e-6
0.0
1.0e-7
0.1
1.0e-8
Cumulative Probability Density
0.9
Cancer Risk
Histogram (E8 (table 36).sta)
y = 761 * 0.000009 * lognorm (x, -12.33735, 1.30935)
100%
80%
70%
70%
40%
Cancer Risk (Truncated at 1e-4)
(N for Risk > 1e-4 = 24)
Cancer Risk (Truncated at N > 1e-4)
(N for Risk > 1e-4 = 7)
5-36
1e-4
9e-5
8e-5
0
1e-4
9e-5
8e-5
7e-5
0%
6e-5
0%
5e-5
10%
4e-5
10%
3e-5
20%
2e-5
20%
7e-5
30%
6e-5
30%
50%
4e-5
40%
60%
3e-5
50%
2e-5
60%
1e-5
Probability Density
80%
1e-5
With Decks
90%
5e-5
Without Decks
0
Probability Density
90%
Histogram (E8 (table 36).sta)
y = 713 * 0.00001 * lognorm (x, -11.54723, 1.21188)
100%
5.4
Summary
The potentially exposed population for this assessment was assumed to be children (ages
1-6 years) in the United States who contact CCA-treated wood and/or CCA-containing soil from
public playsets (e.g., at a playground, a school, a daycare center). A subset of these children was
also assumed to contact CCA-treated wood residues and/or CCA-containing soil from residential
playsets (i.e., at the child's own home or at another home) and/or residential decks (i.e., at the
child's own home or another home). This population was selected because of the particular focus
by CPSC and other groups on playground playsets in conjunction with EPA's focus on estimating
the risk to children from various primary sources of CCA-treated wood (Zartarian et al., 2003).
Noncancer and cancer risks to children exposed to CCA-treated playsets and decks were
calculated from doses generated using the SHEDS-Wood model. Noncancer risks were evaluated
against OPP’s guidance MOE values for arsenic and Cr(VI) for short- (1 day to 1 month) and
intermediate-term (1 to 6 months) exposure duration. Lifetime (6 years of exposure averaged
over 75 years) cancer risk from arsenic exposure was compared to risks ranging from 10-6 to 10 -4.
Noncancer risk for arsenic was above the guidance MOE of 30 for all exposure scenarios, up to
the 99th percentile. Cr(VI) risks were above the guidance MOE of 100 for all doses. Cancer risk
exceeded the upper bound of the risk range, 10 -4, at cumulative percentiles ranging from the 90 th
for warm climate conditions and exposure to decks and playsets to the 99th for cold climate
conditions and exposure to playsets only. Across all exposure scenarios, cancer risks were less
than 10-6 at cumulative percentiles of the 9th and lower. Conversely, approximately 91% of the
simulated exposures had risks exceeding 10-6.
A screening level analysis comparing the risks from soil exposure versus residue exposure
was conducted. Residue risk was greater than soil risk for both categories of exposure. For
playset and deck exposure, residue risks were approximately an order of magnitude greater;
slightly lesser differences were seen for playset only exposure. At the 95th percentile, soil risks
exceeded 10-5 for both categories of exposure and residue risks were slightly greater than 10 -4 for
playset and deck exposure.
Cancer risk was also evaluated using a lower dermal absorption factor for arsenic. When
this factor was reduced by approximately two orders of magnitude, risks were reduced by up to
30% at the 95 th percentile for exposure to playsets and decks. Lesser risk reduction was seen at
the 50th percentile.
5-37
6.0 RISK REDUCTION IMPACTS
6.1
Introduction
The Agency describes risk reduction impacts in this chapter to aid the risk manager in
identifying techniques to reduce risk, given the potential concerns based on cancer risk (see
Chapter 5.0) from contact with CCA-treated wood. The effect of the mitigation strategies was
only assessed for carcinogenic risks from arsenic, because the noncancer MOEs for arsenic and
chromium were above OPP’s guideline values. This Section presents background information
regarding factors that may influence arsenic and chromium levels on or near CCA-treated wood.
The impact of the various mitigation strategies considered are presented in Section 6.2.
There are many variables that can influence the amount of dislodgeable arsenic and
chromium levels present in CCA-treated wood surfaces and in the soil residues from chromated
arsenical wood products. These variables include:
•
•
•
•
•
•
•
•
•
•
Level of retention of arsenic and chromium in the wood;
Different types of CCA (e.g., CCA type A, B, or C);
Different types of pressure treated wood (douglas fir, southern pine, western
cedar, red oak, etc.);
Variables in pressure treatment process (e.g., temperature and pH, air seasoning
time, removal of water, oven drying, etc.) influence the retention of CCA in the
wood;
Use of a salt or an oxide formulation of CCA;
Weather conditions (e.g, acid rain, wet wood can greatly increase the amount of
dislodgeable residues);
Different uses of wood (wood decks, construction or utility poles, marine timbers,
fence posts, wood foundation lumber, plywood, and wood for playground
structures, etc.);
Age of the wood;
Physical condition of the wood (e.g., sanding, surface dirt, or sawing); and
Application of sealant (with oil-based or water-based).
Some of these variables, such as the pressure treatment, level of retention, the type of
wood, age of wood, weather conditions, and formulation of CCA, are variables that are not
controlled by the typical homeowner. However, there may be things that a homeowner can do to
control or reduce the risks from CCA-treated wood in playsets and decks. The Introduction and
Background Chapter (Chapter 2.0) summarized some of the state regulatory agency
recommendations for homeowners to reduce risks to CCA-treated wood. These
recommendations include:
6-1
•
•
•
•
•
•
•
•
•
•
Sealing CCA-treated structures (decks and playsets) every two years with
oil-based stain;
Preventing exposure to pressure-treated wood and dust;
Washing hands after playing on wooden playground equipment;
Inspecting structures for decay;
Using alternatives to CCA-treated pressure treated wood;
Not placing food, drink or paper products on pressure treated wood;
Never burning treated wood;
Limiting use of under deck areas where arsenic may have accumulated in soil;
Not using treated wood on indoor surfaces; and
Not using CCA-treated wood for wood chips or mulch.
In addition, to providing recommendations to homeowners on how to reduce risks to
CCA-treated wood, some states also have codified laws designed to reduce exposure and
eliminate some types of CCA-treated wood. States such as California, Florida, Maine, Minnesota,
and New York either have laws or are introducing legislation that eliminate the supply of certain
types of CCA-treated wood or require the application of sealants to playground/recreation
equipment made with CCA-treated wood (See Chapter 2.0).
Because of the potential concerns based on arsenic cancer risk (see Chapter 5.0) from
contact with CCA-treated wood, the Agency is considering risk reduction impacts in this chapter
to aid risk managers in identifying techniques to reduce risk. Obviously many of the
recommendations to reduce arsenic are based on the activities of the homeowner that are not
readily quantified. In 2001, the FIFRA SAP identified the need for information on the
performance and efficacy of different types and brands of coatings (U.S. EPA, 1991c). EPA
completed the protocol for ongoing research on the effectiveness of sealants on weathered CCAtreated wood. For the purposes of this risk assessment, assumptions were made with regard to
the effectiveness of sealants. These assumptions were based on data such as Stilwell (1998) who
reported over a 95% reduction for oil-based alkyl resins for samples tested one year after a sealant
was applied. CDHS (1987) reported 96%, and 82% reduction from stained treated wood
surfaces after one month and 2 years, respectively. Based on these two existing data sources,
OPP assumed a 90% reduction in residues for a moderate reduction scenario, and a 99.5%
reduction in residues for a maximum reduction scenario. These reductions in residue
concentration were assumed to be constant over time. SHEDS-Wood estimated exposures based
on residue reduction resulting from the use of sealants and/or hand washing. The risks associated
with these reduced exposures are presented in Section 6.2.
6.1.1 Application of Sealant and Hand Washing Information to SHEDS-Wood
The FIFRA SAP recommended that “EPA inform the public of the ability of certain
coatings to substantially reduce leachable and dislodgeable CCA chemicals and thus reduce
6-2
potential exposures to arsenic and chromium.” While the Panel made recommendations regarding
the need for additional studies in this area, it felt that the current evidence was sufficient to begin
advising the public about the use of coatings. The Panel made the following observations.
•
•
The weight-of-evidence from available studies indicated that certain coatings can
substantially reduce dislodgeable and leachable CCA chemicals.
Reductions of 70 to 95% or greater in dislodgeable arsenic were seen in all studies
that subjected CCA wood to natural weathering. (U.S. EPA, 2001c).
Table 6-1 presents the results of the SAP’s analysis of the available sealant studies. The
Panel indicated that “there is no evidence that water repellents added directly to the treatment
solution are effective in reducing leachable/dislodgeable CCA chemicals; current data are not
adequate for identifying a particular coating as being clearly superior or inferior to reducing
leachable/dislodgeable CCA chemicals. However, confidence is highest for polyurethane, as this
coating was shown to result in substantial (70 to >95%) reduction in dislodgeable arsenic in a well
controlled field study (a “real-world” application allowing for effects of use, and a short-term
controlled laboratory study)” (U.S. EPA, 2001c).
Based on the results of the FIFRA SAP, EPA assumed a moderate reduction (90%
reduction in residue concentrations with sealant for warm climates only) and a maximum feasible
reduction (99.5% reduction in residue concentration with sealant for warm climates only) and
incorporated this into the SHEDs-Wood model.
Hand washing was modeled in SHEDS-Wood. The SHEDS-Wood report (see Zartarian
et al., 2003) specifically described how hand washing was estimated (Zartarian et al., 2003).
Below is an excerpt from the text that describes the SHEDs-Wood modeling:
“SHEDS–Wood is essentially a mass balance model that involves simulating the
movement and fate of the pollutant of interest after it has come into contact with the
exposed individual. The SHEDS-Wood model follows simulated individuals through time,
keeping track of the additions and subtractions to the cumulative exposure loading. An
‘exposure’is a new contact with the target chemical; hence ‘exposure’can only occur at
places where the chemical is present (in this case, decks or playsets). Once exposure
occurs, the chemical remains present on or in an individual until it is removed. The
cumulative exposure loading is the total amount of the chemical currently in contact with
the person; this can be non-zero even when away from decks and playsets. It is analogous
to a bank balance, with new exposures corresponding to deposits and removal processes
to withdrawals. In the equations below, a distinction is made between the amount of
new exposure E from a single macroactivity event, and the current loading or cumulative
exposure CE . The size of CE cannot be determined solely from the record of exposures,
but depends on the frequency and size of the removal terms (the withdrawals in the bank
account analogy).
6-3
Table 6-1. Summary of Sealant Studies
Study
Design
Weathering
Sampling
Treatments
Results
> 95% reduction for
polyurethane, acrylic resin, and
varnish at all time points as
compared to pretreatment. 8097% reduction for oil stain.
Comments
Does not account for wear.
Lacks temporal control.
Aesthetic problems after 1 yr for spar
varnish.
Stilwell, 1998 (CT) Purchased boards, placed outside,
4 coatings,
4 replicates, 5 time points out to 1
year
Outside, natural
weathering,
no human use
Standardized wipe
method. Repeat rubbing
of same surface under
controlled pressure
Polyurethane, acrylic
latex, Spar varnish, Oilbased stain. Brush
applied, 2 coats.
California DHS,
1987 (CA)
Fishing pier, 1 coating,
4 replicates, 2 time points out to 2
years
Outside, natural
weathering, in use
Gauze wipe, 100 cm2,
with repeat rubbing to
same surface
Polyurethane, no
> 95% reduction at 2 years as
information on application compared to pretreatment levels.
methods
Considers wear.
Lacks temporal control.
Limited sample sizes and coatings.
California DHS,
1987 (CA)
Single playground, 1 coating,
? replicates, 3 time points, out to 2
years
Outside, natural
weathering, in use
Gauze wipe, 100 cm2,
with repeat rubbing of
same surface
Oil-based stain, no
> 95% reduction at 6 months as
information on application compared to pretreatment levels.
methods.
70% reduction at 2 years.
Considers wear.
Lacks temporal control.
Limited sample sizes and coatings.
SCS, 1998 (lab) as
cited in U.S. EPA
2001c
Purchased boards, used in
laboratory, 3 coatings,
5 replicates, 1 time point
apparently soon after coating
applied.
Inside, no weathering,
not subject to human
use.
Kimwipes,100 cm2, damp.
Hand wipes, 500 cm2,
repeat rubbing of same
surface
3M sealant, Superdec
stain, no information on
application methods,
Osmose water repellant
60% - 80% reduction for 3M
sealant as compared to
pretreatment. No reduction for
stain or water repellent.
Variable within type of coating.
Does not account for wear. Not
subject to natural aging and
weathering. Short-term evaluation.
Cooper et al., 1997 Laboratory prepared wood, fence
(New Brunswick,
& deck structures, placed outside,
CAN)
1 coating,
? replicates, 2 time points, 4 mo,
2 yrs
Laboratory simulated
aging, plus outside,
natural weathering,
no human use.
Collection of natural rain
water contacting wood
surface
Thompson's Water Seal
(fence only) &
Water Repellent in CCA
treatment soln (fence &
deck).
70% reduction at 4 months and
80% reduction at 2 years for
Thompson’s.
No reduction for water repellent
added into treatment solution.
Does not account for wear. Includes
temporal control.
Riedel et al., 1991
(Ontario, CAN)
10 playgrounds, 2 to 10 years old.
Some stained/painted, others not.
4 sampling points per structure.
Outside, natural
weathering, in use
Gauze wipe, 250 or 500
Oil based stain on some
cm2 with repeat rubbing of though not all structures.
same surface
4 structures treated with stain had
on average 74% lower levels of
dislodgeable As than average of 3
structures without any coating. a
Cross-sectional study with no site
specific controls. Limited information
on past application of coatings.
Sampling locations vary across sites.
CPSC, 1990 (lab)
Purchased boards, used in
laboratory, 2 treatments,
3 replicates, 2 wood types.
Inside, no weathering,
not in use, no aging
Nylon cloth wipe, 400
cm2
Oil-based stain, water
repellant, applied per
manufacturer’s label.
No clear evidence of reductions.
Considerable variability in the
controls, short-term study with no
weathering.
Lebow and Evans,
1990 as cited in
U.S. EPA 2001c
Laboratory prepared wood
1 treatment,
? replicates,
1 time point at 17 weeks.
Laboratory simulated
rainfall for 17 weeks.
Collection of natural rain
water contacting wood
surface
Water soluble acrylic
polymer applied pre-CCA
treatment.
25-30% reduction in total As
leached in artificial rainfall.
Coating applied pre-CCA treatment, so
of limited relevance to post-treatment
coatings.
Source: U.S. EPA, 2001c (pp. 53-54); see Appendix F for text and references.
6-4
New dermal exposure, once contacted, remains on the skin until removed by one of a
competing set of processes. These include washing and bathing, hand-to-mouth transfer,
physical removal when load limits are exceeded, and dermal absorption. Because these
processes compete, an increase in the frequency of hand washing will produce deceases in
the amounts that can be removed by the other processes. Thus, the impact of washing on
the absorbed dose can be estimated directly. For ingested (GI tract) exposures, the
removal processes are gastrointestinal absorption and daily voiding of the GI tract.
The basis for the changes to the cumulative exposure loading is the macroactivity time
step, or event. Within a single time step, the SHEDS-Wood model does not model
processes as continuous changes in time, but instead treats them as a sequence of
instantaneous adjustments or changes to the cumulative loading, one for each process
under consideration. The order of the adjustments is: first, new exposure contact (if any)
is added; second, the cumulative loadings are compared to the maximum dermal loading
limits and reduced if necessary; third, the effects of absorption are determined; fourth,
hand-to-mouth transfer occurs; fifth, hand washing (if present); and sixth, bathing (if
present). The presence and the size of each adjustment is based on the activity events
reported in the human activity diaries taken from the CHAD database and on the settings
of several of the input variables” (Zartarian et al., 2003).
OPP was able to use the exposures of SHEDS-Wood to evaluate the effect of hand
washing on cancer risks.
6.2
Risk Characterization for Mitigation Measures
Many of the methods to reduce arsenic exposure are based on the activities of the
homeowner that are not readily quantified. SHEDS-Wood simulated reduced exposure doses
resulting from two mitigation measures: the use of sealants and/or hand washing. These
mitigation measures only apply to residue exposure and not to soil exposure. Although soil
exposure may potentially be reduced through removal of contaminated soil, this was not modeled
in SHEDS-Wood. The use of sealants may also reduce the rate of transfer of CCA to the
adjacent soil over time, however, there are no available studies documenting this effect. The
approach taken in SHEDS-Wood was conservative: exposures were most likely overestimated
because soil concentrations were held constant while wood residue concentrations were reduced.
Another issue is how SHEDS-Wood treated soil exposure. Residue exposures were assumed to
be transferred to the gastrointestinal tract via hand-to-mouth behavior, but this was not the case
for soils. Instead, soil ingestion was treated as a single term that included both direct eating of
soil as well as soil-hand-mouth transfers.
6-5
Increased hand washing, as a mitigation strategy, was also evaluated. The way in which
SHEDS-Wood handled hand washing was by only reducing residue exposure and not soil exposure.
One supposes that hand washing could also provide some reduction in the soil-hand-mouth pathway,
but this was not explicitly modeled in SHEDS-Wood.
Two types of mitigation measures that were evaluated: reducing exposure through the use
of sealants and through hand washing. Table 6-2 summarizes the various mitigation measures
considered.
Table 6-2. Arsenic Mitigation Measures Evaluated
Title
Description
1. Sealant- moderate reduction
Assumed sealant afforded a 90% reduction in residue
concentration.
2. Sealant – maximum reduction
Assumed sealant afforded a 99.5% reduction in residue
concentration.
3. Hand washing
Increased frequency of hand washing.
4. Sealant-moderate + hand washing
90% reduction in residue concentration with increased
frequency of hand washing.
5. Sealant-maximum + hand washing
99.5% reduction in residue with increased frequency of
hand washing.
Risks based on mitigation strategies are presented in a similar format as in Chapter 5. First,
for each mitigation measure considered, results are shown at four levels of exposure corresponding
to the mean, median, 95th percentile and 99th percentile. Second, the CDF/PDFs are plotted. Lastly,
a comparison of risks due to soil exposure versus residue exposure is presented.
6-6
6.2.1 Summary of Results
Results for the various mitigation scenarios are summarized in Table 6-3. Mitigation
measures were only evaluated for the warm climate because this condition had the highest levels of
risk. The table is shown in two parts: the top portion is for risk from exposure to playsets only and
the lower portion is for risk from exposure to playsets and decks. Carcinogenic risks from arsenic
are compared to the three levels of risk 10-6, 10-5, and 10-4 in Table 6-3. Values reported in the table
are the cumulative probabilities above which the respective risk level is exceeded. Note that when
exposure includes both playsets and decks (i.e., greater exposure), the cumulative percentile
exceeding the risk level decreased at all levels except at 10-4. The 10-4 risk level was at the extreme
tail of the distributions under all mitigation conditions. It was slightly less extreme for hand washing
only; for that mitigation scenario, the 10 -4 risk level fell at the 95th percentile.
Table 6-3. Summary of Risks Assuming Different Arsenic Mitigation Measures
for Warm Climate Conditions
Cumulative Percentiles at Specified Risk Levels
Risk Level of
Risk Level of Risk Level of
10-6
10-5
10-4
Playset Only
1. Sealant- moderate reduction
27th
94th
>99th
2. Sealant – maximum reduction
57th
97th
>99th
3. Hand washing
5th
59th
>99th
4. Sealant-moderate + hand washing
28th
92nd
>99th
5. Sealant-maximum + hand washing
58th
96th
>99th
6. Baseline
3rd
47th
97th
Playset and Deck
1. Sealant-moderate reduction
10th
80th
>99th
2. Sealant-maximum reduction
42nd
94th
>99th
3. Hand washing
<1st
28th
95th
4. Sealant-moderate + hand washing
10th
84th
>99th
5. Sealant-maximum + hand washing
44th
93rd
>99th
6. Baseline
<1st
23rd
90th
Mitigation Measure
Note: The baseline scenario includes a certain amount of hand washing. Hand washing, as a mitigation scenario, increases the
frequency of this activity over baseline. See Appendix G for more information on hand washing.
6-7
The evaluation of risk remaining after the simulated mitigation measure was considered in
reference to the baseline risk (i.e., no mitigation) discussed in Chapter 5. The following discussion
focuses on the 10-6 risk level for comparison among the mitigation measures to baseline. For
reference, the baseline percentiles at the 10-6 level (see Table 5-1) for warm climate conditions
were the 3rd for playset only exposure and less than the 1st for exposure to playsets and decks.
Several observations were made regarding the risks remaining following simulated mitigation
measures. First, as would be expected, the greatest risk reduction occurred with the sealant under
maximum residue reduction (99.5%). For example, for playset only exposure, the 10 -6 risk level
occurred at the 57 th percentile with this mitigation as compared to the 3 rd percentile for the
baseline condition. For exposure to decks and playsets, the comparable percentile was the 42th.
Second, hand washing provided the least reduction of risk; for playsets alone, the 10-6 risk level
occurred at the 5 th percentile and less than the 1st percentile for decks and playset exposure.
Third, the simulation of combining sealant mitigation with hand washing had minimal impacts on
the percentiles for the 10-6 risk level.1
6.2.2 Risk Reduction Through the Use of Sealants
Cancer risks for arsenic for children in warm climates were assessed for a moderate
reduction in residue concentration (90% reduction in residue concentration) and a maximum
reduction in residue concentration (99.5% reduction in residue concentration) to simulate the use
of sealants. Table 6-4 presents the risks under the assumption of moderate and maximum
reduction of exposure for the mean, median, and 95 th percentile, and 99th percentile. For the
maximum reduction simulation, risks were found to be within EPA’s risk range for the four
exposure levels shown here. Comparing risks from exposure to playsets and decks to exposure to
playsets only, shows that the playset only risks were approximately 2 times less than the combined
exposure. For the moderate reduction simulation, risks were still found to be within EPA’s risk
range for the four exposure levels shown here. Risk from exposure to playsets and decks were
again approximately 2 times greater than risks from exposure to playsets alone. For comparison,
baseline risks at the 95th percentile were 1.4 x 10-4 for playset and deck exposure and 8.3 x 10-5
for playsets only. At the 95th percentile, under the maximum reduction simulation, risks were
reduced by approximately an order of magnitude over baseline.
1
This may be due to the way SHEDS-Wood simulated the effect of hand washing, as
noted in Section 6.2.
6-8
Table 6-4. Cancer Risks Remaining Following Simulated Reduction in Residues
from the Use of Sealants (Warm Climate only)
Arsenic (Q1*= 3.67 (mg/kg/day)-1)
Scenario
Mean
Median
95%ile
99%ile
Moderate
Reduction
Maximum
Reduction
Moderate
Reduction
Maximum
Reduction
Moderate
Reduction
Maximum
Reduction
Moderate
Reduction
Maximum
Reduction
Playsets and
Decks
6.6E-06
2.9E-06
3.9E-06
1.3E-06
2.1E-05
1.1E-05
3.7E-05
2.9E-05
Playsets only
3.3E-06
2.0E-06
2.0E-06
8.1E-07
1.1E-05
8.2E-06
2.1E-05
1.7E-05
The cumulative probability density and probability density plots for moderate reduction
and maximum reduction are shown in Figures 6-1 and 6-2, respectively. The probabilistic arsenic
cancer risk distributions for moderate and maximum reduction are provided in Tables 6-5 and 6-6,
respectively. Risks for both sources of exposure, playset only (without decks) and playset and
deck (with decks) are plotted on the cumulative density plot. Under moderate reduction (Figure
6-1), the lower limit of EPA’s risk range fell in the lower percentile range; at the 27th percentile
for playset only exposure and at the 10th percentile for the combined exposure. For comparison,
the corresponding percentiles under the baseline conditions were the 3rd for playset only exposure
and less than the 1st for exposure to playsets and decks. At the maximum assumed reduction
(Figure 6-2), the curve shifted to the left, so that the 10 -6 risk occurred near the 50 th percentile for
both sources of exposure. For playsets only, it was slightly higher (57th percentile) and for playsets
and decks it was slightly lower (42nd percentile). Risks exceeded the risk 10-4 range only for the
moderate reduction assumption above the 99 th percentile; under the maximum assumed reduction,
risks did not exceed the risk range.
6-9
Figure 6-1
Cancer Risk from Lifetime-Term LADD for Children Exposed to Arsenic
Dislodgeable Residues and Contaminated Soil from Treated Wood
Playsets and Residential Decks in Warm Climate
(Reducing Deck and Playset Residue Concentration by 90%)
Scatterplot (E9 (table 37).sta)
1.0
Without Decks
99% = 2.1x10-5
95% = 1.1x10-5
50% = 2.0x10-6
mean = 3.3x10 -6
With Decks
99% = 3.7x10-5
95% = 2.1x10-5
50% = 3.9x10-6
mean = 6.6x10 -6
0.8
0.7
0.6
0.5
0.4
0.3
Without Decks
With Decks
0.2
1.0e-4
1.0e-5
1.0e-6
1.0e-7
0.0
1.0e-3
hmdeck=0
hmdeck=1
0.1
1.0e-8
Cumulative Probability Density
0.9
Cancer Risk
Histogram (E9 (table 37).sta)
Histogram (E9 (table 37).sta)
y = 700 * 0.000001 * lognorm (x, -13.18276, 1.118033) y = 759 * 0.000002 * lognorm (x, -12.4577, 1.058113)
100%
100%
80%
70%
70%
30%
Cancer Risk (Truncated at 1e-5)
(N for Risk > 1e-5 = 40)
Cancer Risk (Truncated at 2e-5)
(N for Risk > 2e-5 = 41)
6-10
2e-5
1.8e-5
0
1e-5
9e-6
8e-6
7e-6
6e-6
5e-6
4e-6
3e-6
0%
2e-6
10%
0%
1e-6
10%
1.6e-5
20%
1.4e-5
20%
40%
1.2e-5
30%
50%
8e-6
40%
60%
6e-6
50%
4e-6
60%
2e-6
Probability Density
80%
0
Probability Density
With Decks
90%
1e-5
Without Decks
90%
Figure 6-2
Cancer Risk from Lifetime-Term LADD for Children Exposed to Arsenic
Dislodgeable Residues and Contaminated Soil from Treated Wood
Playsets and Residential Decks in Warm Climate
(Reducing Deck and Playset Residue Concentration by 99.5%)
Scatterplot (E10 (table 38).sta)
1.0
Without Decks
99% = 1.7x10-5
95% = 8.2x10-6
50% = 8.1x10-7
mean = 2.0x10-6
With Decks
99% = 2.9x10-5
95% = 1.1x10-5
50% = 1.3x10-6
mean = 2.9x10-6
0.8
0.7
0.6
0.5
0.4
0.3
Without Decks
With Decks
0.2
1.0e-5
1.0e-6
1.0e-7
0.0
1.0e-8
0.1
1.0e-4
hmdeck=0
hmdeck=1
1.0e-9
Cumulative Probability Density
0.9
Cancer Risk
70%
30%
Cancer Risk (Truncated at 1e-5)
(N for Risk > 1e-5 = 26)
Cancer Risk (Truncated at 1e-5)
(N for Risk > 1e-5 = 41)
6-11
1e-5
0
1e-5
9e-6
8e-6
7e-6
6e-6
5e-6
4e-6
3e-6
2e-6
0%
1e-6
10%
0%
9e-6
20%
10%
8e-6
20%
40%
7e-6
30%
50%
4e-6
40%
60%
3e-6
50%
2e-6
60%
1e-6
Probability Density
80%
70%
0
With Decks
90%
80%
6e-6
Without Decks
90%
Probability Density
Histogram (E10 (table 38).sta)
y = 721 * 0.000001 * lognorm (x, -13.5529, 1.337504)
100%
5e-6
Histogram (E10 (table 38).sta)
y = 743 * 0.000001 * lognorm (x, -14.0379, 1.424257)
100%
Table 6-5. Probabilistic Arsenic Cancer Risk Distributions and Risk Ranges for Children in
Warm Climates (reducing deck and playset residue concentration by 90%) (Based on the
LADDs in Table 37 from the SHEDS-Wood document)
Playset Only
Percentile of
Exposure
maximum
99
95
90
50
10
5
1
minimum
>99.9
94.3
26.9
Lifetime Average Daily Dose Cancer Risk
(LADD) mg/kg/day
1.2E-05
4.2E-05
5.7E-06
2.1E-05
3.0E-06
1.1E-05
2.2E-06
7.9E-06
5.4E-07
2.0E-06
1.1E-07
4.1E-07
7.1E-08
2.6E-07
2.9E-08
1.1E-07
3.3E-09
1.2E-08
1.2E-05
1.0E-04
2.7E-06
1.0E-05
2.7E-07
1.0E-06
Playset and Deck
Percentile of
Lifetime Average Daily Dose Cancer Risk
Exposure
(LADD) mg/kg/day
maximum
3.3E-05
1.2E-04
99
1.0E-05
3.7E-05
95
5.6E-06
2.1E-05
90
4.1E-06
1.5E-05
50
1.1E-06
3.9E-06
10
2.7E-07
9.9E-07
5
1.9E-07
7.1E-07
1
7.9E-08
2.9E-07
minimum
1.9E-08
7.1E-08
99.9
1.9E-05
1.0E-04
80.0
2.7E-06
1.0E-05
10.0
2.7E-07
1.0E-06
A = 1.0e-6
Risk Range
B = 1.0e-5 C = 1.0e-4
Risk Range
A = 1.0e-6 B = 1.0e-5 C = 1.0e-4
Note: Shaded area indicates all the percentiles of the population that meet the risk level set by the Agency.
6-12
Table 6-6. Probabilistic Arsenic Cancer Risk Distributions and Risk Ranges For Children
in Warm Climates (Reducing Deck and Playset Residue Concentration by 99.5%)(Based on
LADDs in Table 38 from the SHEDS-Wood document)
Playset Only
Percentile of
Exposure
maximum
99
95
90
50
10
5
1
minimum
>99.9
96.5
56.8
Lifetime Average Daily Dose Cancer Risk
(LADD) mg/kg/day
9.0E-06
3.3E-05
4.6E-06
1.7E-05
2.2E-06
8.2E-06
1.4E-06
5.3E-06
2.2E-07
8.1E-07
3.8E-08
1.4E-07
2.4E-08
8.6E-08
6.1E-09
2.2E-08
9.8E-10
3.6E-09
9.0E-06
1.0E-04
2.7E-06
1.0E-05
2.7E-07
1.0E-06
Playset and Deck
Percentile of
Lifetime Average Daily Dose Cancer Risk
Exposure
(LADD) mg/kg/day
maximum
1.0E-05
3.8E-05
99
7.8E-06
2.9E-05
95
2.9E-06
1.1E-05
90
1.9E-06
6.9E-06
50
3.6E-07
1.3E-06
10
6.4E-08
2.3E-07
5
4.3E-08
1.6E-07
1
1.4E-08
5.0E-08
minimum
2.8E-09
1.0E-08
>99.9
1.0E-05
1.0E-04
94.3
2.7E-06
1.0E-05
42.3
2.7E-07
1.0E-06
Risk Range
A = 1.0e-6 B = 1.0e-5 C = 1.0e-4
A = 1.0e-6
Risk Range
B = 1.0e-5 C = 1.0e-4
Note: Shaded area indicates all the percentiles of the population that meet the risk level set by the Agency.
6-13
6.2.3 Risk Reduction Through Hand Washing
Note: The baseline scenario includes a certain amount of hand washing. Hand washing, as a
mitigation scenario, increases the frequency of this activity over baseline. See Appendix G for
more information on hand washing.
Arsenic residues can be transferred from surface of wood to the surface of hands and
subsequently be ingested by children through hand-to-mouth activity (in SHEDS-Wood, hand
washing did not effect soil exposures, as noted in Section 6.2). The effectiveness of increased
hand washing at reducing exposure, and thus, risk was evaluated. Table 6-7 presents the risks
based on reduction by hand washing alone at the mean, median, 95th percentile, and 99th
percentile. Risks for exposure to playsets and decks was approximately 2 times greater than risks
to playsets alone. Risks were within EPA’s risk range of 10-6 to 10 -4 at all points except above the
95th percentile for exposure to playsets and decks. Baseline risks at the 95th percentile, for
comparison, were 1.4 x 10-4 for exposure to playsets and decks and 8.3 x 10-5 for playsets alone.
The pattern was similar at the other estimates of exposure. These baseline risks were only slightly
greater than the risks when exposure was reduced by hand washing.
Table 6-7. Cancer Risks Remaining Following Simulated Reductions from Hand Washing
(Warm Climate Only)
Arsenic (Q1*= 3.67 (mg/kg/day) -1)
Mean
Median
95%ile
99%ile
Playsets and decks
3.1E-05
1.8E-05
1.0E-04
2.6E-04
Playsets only
1.3E-05
7.5E-06
4.6E-05
7.3E-05
Scenario
Note: The baseline scenario includes a certain amount of hand washing. Hand washing, as a mitigation scenario, increases the
frequency of this activity over baseline. See Appendix G for more information on hand washing.
The cumulative probability function and probability density plots for the hand washing
mitigation measure are shown in Figure 6-3. Cumulative percentiles and associated risks are
compared to risk levels from 10-6 to 10 -4 in Table 6-8. The cumulative probability at the 10-6 risk
level was found to be at the very low end of the distribution: less than the 1st percentile for
exposure to decks and playsets, and the 5th percentile for exposure to playsets alone. For the
baseline scenario, the comparative percentiles were very similar: less than the 1st percentile for
deck and playset exposure and 3rd percentile for playset only exposure.
6-14
Figure 6-3
Cancer Risk from Lifetime-Term LADD for Children Exposed to Arsenic
Dislodgeable Residues and Contaminated Soil from Treated Wood
Playsets and Residential Decks in Warm Climate
(Reducing Exposure by Washing Hands after Playing on Deck or Playset)
Scatterplot (E11 (table 39).sta)
1.0
Without Decks
99% = 7.3x10-5
95% = 4.6x10-5
50% = 7.5x10-6
mean = 1.3x10-5
With Decks
99% = 2.6x10-4
95% = 1.0x10-4
50% = 1.8x10-5
mean = 3.1x10-5
0.8
0.7
0.6
0.5
0.4
Without Decks
With Decks
0.3
hmdeck=0
hmdeck=1
0.2
1.0e-3
1.0e-4
1.0e-5
1.0e-6
0.0
1.0e-7
0.1
1.0e-8
Cumulative Probability Density
0.9
Cancer Risk
80%
70%
70%
30%
Cancer Risk (Truncated at 1e-4)
(N for Risk > 1e-4 = 3)
Cancer Risk (Truncated at 1e-4)
(N for Risk > 1e-4 = 36)
6-15
1e-4
0
1e-4
9e-5
8e-5
7e-5
6e-5
5e-5
4e-5
3e-5
0%
2e-5
10%
0%
1e-5
10%
9e-5
20%
8e-5
20%
40%
7e-5
30%
4e-5
40%
50%
3e-5
50%
60%
2e-5
60%
1e-5
Probability Density
80%
0
With Decks
90%
6e-5
Without Decks
90%
Probability Density
Histogram (E11 (table 39).sta)
y = 704 * 0.00001 * lognorm (x, -10.94873, 1.041763)
100%
5e-5
Histogram (E11 (table 39).sta)
y = 747 * 0.00001 * lognorm (x, -11.8072, 1.17881)
100%
Table 6-8. Probabilistic Arsenic Cancer Risk Distributions and Risk Ranges for Children
in Warm Climates (Reducing Exposure by Washing Hands After Playing on Deck or
Playset) (Based on LADDs in Table 39 from the SHEDS-Wood document)
Playset Only
Percentile of
Exposure
maximum
99
95
90
50
10
5
1
minimum
99.6
58.5
5.1
Lifetime Average Daily Dose Cancer Risk
(LADD) mg/kg/day
4.6E-05
1.7E-04
2.0E-05
7.3E-05
1.2E-05
4.6E-05
9.2E-06
3.4E-05
2.1E-06
7.5E-06
4.7E-07
1.7E-06
2.7E-07
1.0E-06
7.7E-08
2.8E-07
7.0E-09
2.6E-08
2.4E-05
1.0E-04
2.7E-06
1.0E-05
2.7E-07
1.0E-06
Playset and Deck
Percentile of
Lifetime Average Daily Dose Cancer Risk
Exposure
(LADD) mg/kg/day
maximum
1.2E-04
4.5E-04
99
7.0E-05
2.6E-04
95
2.7E-05
1.0E-04
90
1.8E-05
6.5E-05
50
4.8E-06
1.8E-05
10
1.4E-06
5.1E-06
5
9.0E-07
3.3E-06
1
3.1E-07
1.1E-06
minimum
1.3E-07
4.7E-07
94.9
2.7E-05
1.0E-04
28.1
2.7E-06
1.0E-05
0.7
2.6E-07
1.0E-06
A = 1.0e-6
Risk Range
B = 1.0e-5 C = 1.0e-4
A = 1.0e-6
Risk Range
B = 1.0e-5 C = 1.0e-4
Note: Shaded area indicates all the percentiles of the population that meet the risk level set by the Agency.
6-16
6.2.4 Risk Reduction Through Use of Sealants and Hand Washing
The reduction in risk through the use of sealants in combination with hand washing was
simulated for both sealant effectiveness conditions, moderate (90% reduction in residue
concentration) and maximum (99.5% reduction in residue concentration). Risks from the
combined mitigation measures did not differ greatly from the sealant only mitigation. Therefore,
the results of the combined mitigation measures are summarized below with the full results
contained in Appendix C. Table 6-9 presents a comparison of the sealant alone percentiles to the
sealant and hand washing percentiles at two risk levels, 10-6 and 10-5. The highest risk level of the
risk range, 10-4, was not included because all percentiles were greater than the 99th for these
mitigation measures. Table 6-9 shows that, at the 10 -6 risk level, adding hand washing increased
the cumulative percentile (i.e., reducing risk) by less than 4% under the moderate sealant
assumption and less than 2% at the maximum. At the 10 -5 level, the cumulative percentiles
decreased slightly. This is an artifact of a Monte Carlo simulation model. These differences are so
small, and given the uncertainty in the model, it is concluded there are no substantive differences
in mitigation effectiveness of sealants in combination with hand washing.
Table 6-9. Comparison of Cancer Risks from Combined Mitigation Measures
at 10-6 and 10-5 Risk Levels
Cumulative Percentile
Risk Level
Moderate
Reduction
Cumulative Percentile
Moderate + Difference Maximum Maximum + Difference
Hand wash
Reduction Hand wash
10-6
27
28
3.7%
57
58
1.8%
10-5
94
92
-2.1%
97
96
-1%
Note: The baseline scenario includes a certain amount of hand washing. Hand washing, as a mitigation scenario,
increases the frequency of this activity over baseline. See Appendix G for more information on hand washing.
Appendix C contains further detail on these combined mitigation measures: the tables of
mean, median, 95th percentile, and 99th percentile and the cumulative probability density and
probability density plots.
6-17
6.3
Comparison of Residue and Soil Risks
The most significant exposure route for the population of interest for most scenarios (As
and Cr, warm and cold, all time periods) was residue ingestion via hand-to-mouth contact,
followed by dermal residue contact. Zartarian et al. (2003) found that under baseline conditions,
doses from residues were shown to be from a factor of 6 to a factor of 10 greater than soil doses,
depending on the source of exposure. Thus, it was of interest to examine how the distribution of
risks changed under the assumed mitigation conditions.
The various mitigation measures were evaluated for the differing contribution to total risk
from dislodgeable residues. This is the same type of analysis as was conducted for the baseline
condition discussed in Chapter 5. In this chapter, only the maximum and moderate reduction
sealant simulation results are presented; figures for all other mitigation measures are shown in
Appendix D. Figures 6-4 and 6-5 are line graphs of the estimated cumulative probability density
for the maximum and moderate sealant mitigation conditions, respectively. Figure 6-4 clearly
shows that exposure to soil accounts for the majority of risk when exposure to residues is reduced
by 99.5%. The difference in residue risk between playset only and playset and deck exposures
were greater for residues than for soil. Under the moderate residue reduction assumption (Figure
6-5), the difference between residue and soil risks was less. Compared to baseline conditions, the
residue risk lines for maximum and moderate reduction shifted to the left (i.e., reduced risk)
significantly (see Figure 5-8, Chapter 5). For example, at the 99th percentile, the playset and deck
residue risk under the maximum reduction was at 10-6; under baseline conditions this same risk
was greater than 10 -4. Figures 6-6 for maximum reduction and 6-7 for moderate reduction are bar
charts for three points from the cumulative distribution curves: median, and 95 th percentile and
99th percentile.
In Figure 6-6, soil risks exceed residue risks at the median by a factor of 200 for playset
only exposure and by a factor of 150 for playset and deck exposure. These differences decrease
to 65 and 50 for playset only and playset and deck exposure, respectively, at the 95th percentile.
This same bar chart shows that at the 95th percentile, soil risk from exposure to decks and playsets
is at 10–5; playset only soil risk is slightly less. In Table 6-10, total risk is compared to residue risk
at four points on the cumulative distribution, mean, median, 95 th percentile, and 99th percentile
under the two reduced residue simulated conditions. These risk levels are for playset and deck
exposure under warm climate conditions. The first line is total risk and the second line is residue
risk. For total risk, the difference between the two mitigation assumptions at the median is a
factor of 3; at the 99 th percentile this decreases to less than a factor of 1.3. These differences are
relatively small because soils now account for the majority of risk (see Figures 6-4 and 6-5). The
residue risks show a larger difference between the moderate and maximum reduction assumption.
At the median, the difference is a factor of 54 and at the 99th percentile the difference decreases to
a factor of 27.
6-18
Figure 6-4 Comparison of Residue & Soil Total Arsenic Risks for Warm Climate
99.5% Reduction
100
90
Residue risk -playset only
Residue risk - decks & playsets
80
Cumulative Probability Density
Soil risk - playset only
70
Soil risk - decks & playsets
60
50
40
30
20
10
0
1.0E-12
1.0E-11
1.0E-10
1.0E-09
1.0E-08
Carcinogenic Risk
6-19
1.0E-07
1.0E-06
1.0E-05
1.0E-04
Figure 6-5 Comparison of Residue & Soil Total Arsenic Risks for Warm Climate
90% Reduction
100
90
Residue risk -playset only
Soil risk - playset only
Cumulative Probability Density
80
Residue risk - decks & playsets
70
Soil risk - decks & playsets
60
50
40
30
20
10
0
1.0E-09
1.0E-08
1.0E-07
1.0E-06
Carcinogenic Risk
6-20
1.0E-05
1.0E-04
Figure 6-6 Comparison of Residue and Soil Arsenic Risks for Warm Climate
99.5% Reduction
1.0E-04
Residue risk -playset only
Soil risk - playset only
1.0E-05
Residue risk - decks & playsets
Soil risk - decks & playsets
Cancer Risk
1.0E-06
1.0E-07
1.0E-08
1.0E-09
50%ile
95%tile
6-21
99%tile
Table 6-10. Comparison of Total Risk to Residue Only Risk
Under Different Mitigation Conditions
(Playsets and Decks - Warm Climate)
Scenario
Mean
Median
95%ile
99%ile
Moderate
Reduction
Maximum
Reduction
Moderate
Reduction
Maximum
Reduction
Moderate
Reduction
Maximum
Reduction
Moderate
Reduction
Maximum
Reduction
Total Risk
(Playsets and
Decks)
6.6E-06
2.9E-06
3.9E-06
1.3E-06
2.1E-05
1.1E-05
3.7E-05
2.9E-05
Residue Risk
(Playsets and
Decks)
3.5E-06
9.5E-08
1.2E-06
2.2E-08
1.4E-05
3.6E-07
3.3E-05
1.2E-06
6-22
Figure 6-7 Comparison of Residue and Soil Arsenic Risks for Warm Climate
90% Reduction
1.0E-04
Residue risk -playset only
Soil risk - playset only
1.0E-05
Residue risk - decks & playsets
Cancer Risk
Soil risk - decks & playsets
1.0E-06
1.0E-07
1.0E-08
1.0E-09
50%ile
95%tile
6-23
99%tile
6.4
Summary
In this chapter, the results from five different mitigation conditions are summarized. Two
of the mitigation conditions simulated the effect of a sealant on reducing exposure to dislodgeable
residues. For moderately effective sealant conditions, residues were assumed to be reduced by
90%; for maximally effective sealant conditions, residues assumed to be reduced by 99.5%. The
other type of mitigation measure simulated was hand washing. In SHEDS-Wood, simulated hand
washing only was applicable to residue exposure and not to soil exposure. Hand washing was
considered alone and in combination with the sealant conditions. These different mitigation
measures were evaluated for the warm climate condition only, as that has the greater exposure,
and associated risk. Soil exposures were assumed to be the same as under baseline (i.e., no
reduction in exposure due to the use of sealants).
In probabilistic risk assessments, risk reduction is seen as a shifting of the cumulative
probability curve towards lower risks (i.e. to the left). Because it is difficult to discuss an entire
curve, the cumulative percentiles were compared at the 10-6 risk level. Table 6-11 presents the
cumulative percentiles at the 10-6 risk level for baseline and each mitigation measure. Increase the
frequency of hand washing alone was the least effective mitigation measure. For the sealant only
mitigation condition, maximum reduction in exposure shifted the cumulative percentile to the 57 th
percentile for playsets alone and the 42nd percentile for playset and deck exposure. There was a
much similar shift for the moderate reduction measure. Hand washing combined with either
sealant mitigation simulation had a minimal effect on the cumulative percentile at the 10-6 risk
level. The differences between baseline conditions and any of the mitigation measures was
consistently less for exposure to both playsets and decks than it was for playsets only.
6-24
Table 6-11. Comparison of Mitigation Measures to Baseline
at the 10-6 Risk Level (Warm Climate)
Baseline
Moderate
Sealant
Reduction
Maximum
Sealant
Reduction
Hand
Washing
Moderate +
Hand
Washing
Maximum +
Hand Washing
Playsets Only
Cumulative
Percentile
3
Mitigation –
Baseline
difference
27
57
5
28
58
24
54
2
25
55
Playsets & Decks
Cumulative
Percentile
Mitigation –
Baseline
difference
1
10
42
<1
10
44
9
41
0
9
43
6-25
7.0 UNCERTAINTY IN THE RISK ASSESSMENT
In risk assessment, uncertainty refers to a lack of knowledge in the underlying science,
while variability considers that some individuals in a population have more or less risk than others
because of differences in exposure, dose-response relationship or both. Uncertainties are inherent
in the risk assessment process. In order to appreciate the limitation and significance of the risk
estimates, it is important to have an understanding of the sources and magnitudes of these
uncertainties. Sources of uncertainty in this risk assessment, include:
•
•
•
•
•
Environmental media sampling and analysis;
Chemical fate;
Toxicity data;
Exposure assessment modeling; and
Risk characterization.
Over the course of EPA’s evaluation of risks from exposure to CCA, the FIFRA SAP has
made recommendations regarding input data and default assumptions used in risk assessment.
These recommendations included criteria to evaluate the quality of data included in the modeling
effort and appropriate decisions to be made in the absence of adequate data. The SAP provided
the Agency with clear criteria to judge data quality in 1999, and these were recognized in support
documents provided to the panel. Under conditions of moderate or high uncertainty (absence of
sufficient data to fully capture the variability in exposure from these sources), the SAP suggested
that the Agency should develop clear default assumptions to be employed until sufficient data are
secured. They also recommended that these assumptions should err on the side of overestimation
of exposure, or factors that contribute to exposure (U.S. EPA, 2001c).
The uncertainty in a risk assessment reflects the combined uncertainty of all the input
variables that are used to estimate an exposure dose combined with the uncertainty of the
toxicological parameters. Zartarian et al. (2003) conducted a thorough uncertainty analysis,
evaluating model sensitivity and uncertainty through hundreds of iterations of the SHEDS-Wood
model. Toxicological parameters have only been evaluated in a qualitative manner due to
constraints of time and resources. Therefore, this uncertainty analysis is considered semiquantitative.
7.1
Environmental Media Sampling and Analysis
Analytical data for chromium and arsenic residues on CCA-treated surfaces, as used in the
SHEDS-Wood model, were taken from several literature sources, as described in Zartarian et al.
(2003). The variability distributions for arsenic and chromium residues and soil concentrations
are shown in Table 7 of Zartarian et al. (2003). Summaries of the sources of data used to develop
7-1
residue and soil concentrations are presented in Table 8 of Zartarian et al. (2003). Likewise, data
for arsenic and chromium residues in CCA-treated decks, as used by SHEDS-Wood to estimate
exposure doses, are described in Zartarian et al. (2003). The data sets used to generate the
exposure point concentrations are described in the SHEDS-Wood exposure report and
summarized in Table 12 of that report. Uncertainty in the exposure point concentration arises
from how accurately these various data sets characterize the soil and dislodgeable residue
concentrations in the underlying population of treated playsets and decks.
There are many significant variables that can affect the measurement of dislodgeable
arsenic and chromium in CCA-treated wood surfaces and in the soil surrounding the treated wood
products. Some of these variables include the following:
•
•
•
•
•
•
•
•
The fraction of arsenic and chromium retained in the wood (retentions of CCA
type C in wood can range anywhere from 0.25-2.50 pounds per cubic foot (pcf)
depending on the different AWPA standards;
The type of CCA formulation used to treat the wood (CCA treatment solutions are
typically classified as either type A, B, or C since they vary in the proportion of
arsenic to chromium compounds; however, CCA type C is most commonly used to
treat dimensional lumber for above-ground residential applications). Data from
type C was most often used in the study data used in this assessment;
The type of pressure-treated wood (e.g., Douglas fir, southern pine, western cedar,
red oak, etc.) can affect leaching and/or transfer of residues;
The end use of wood (e.g., wood decks, construction or utility poles, marine
timbers, fence posts, wood foundation lumber, plywood, and wood for playground
structures or decks) determines the amount of CCA used for treatment;
The degree that the wood has been sanded can affect residue levels;
Variables in the pressure treatment process can influence the retention of CCA in
wood (e.g., temperature and pH, too short of air seasoning time, rapid removal of
water, rapid oven drying, etc.);
The moisture content of the wood can affect CCA content and leaching; and
The age of the CCA-treated wood can affect residue levels and leaching of CCA to
surrounding soil.
To the extent that the data sets used in SHEDS-Wood represent these variables, then
these sources of variability are accounted for. However, it is not known how these factors are
distributed across the underlying population of decks and playsets and if they are represented in
the input data sets.
In addition to the variables mentioned above, wood finishes such as oil stain, varnish, paint
or sealant (e.g., polyurethane, acrylic or spar varnish) applied to pressure-treated wood may
decrease the amounts of dislodgeable residues in CCA pressure-treated wood surfaces. For
7-2
mitigation, this study assumed that sealants can reduce overall residue concentration by 90% and
99.5%. This assumption is based on the results of various studies listed in Chapter 6.0. The
following uncertainties regarding coatings should be considered.
•
•
•
•
•
The weight-of-evidence from available studies indicates that certain coatings can
substantially reduce dislodgeable and leachable CCA chemicals;
Reductions of 70 to 95% in dislodgeable arsenic were seen in all studies that
subjected CCA wood to natural weathering;
There is no evidence that water repellents added directly to the CCA treatment
solution are effective in reducing leachable/dislodgeable CCA chemicals;
Current data are not adequate for identifying a particular coating as being clearly
superior or inferior to reducing leachable/dislodgeable CCA chemicals; and
Confidence is highest for polyurethane as this coating has been shown to result in
substantial 70 to >95% reduction in dislodgeable arsenic in a well controlled field
study, a “real-world” application allowing for effects of use, and a short-term
controlled laboratory study.
There is considerable uncertainty regarding the representativeness of the assumed
exposure reduction based on the use of sealants. The assumed reductions were selected to
evaluate different mitigation control measures. They are reasonable scientific judgements;
however, they are not based on a study that would allow extrapolation to the underlying
population of decks and playsets implied in this study. Therefore, there is higher uncertainty
associated with the dislodgeable residue exposure point concentrations for the mitigation
scenarios than with the residue exposure point concentrations used in the baseline risk assessment.
7.2
Chemical Fate
Conservative assumptions were made regarding the fate of arsenic and chromium in the
environment. For arsenic, it was assumed that concentrations are relatively persistent and
immobile. Thus, individuals were assumed to be exposed to the same concentration for the entire
duration of exposure (i.e., 6 years). For chromium, all studies used to develop the probability
density functions for exposure point concentrations reported total chromium, Cr(III) and Cr(VI).
There was concern that assessing chromium(total) doses would overestimate the exposure.
Therefore, an attempt was made to determine the speciation of chromium in soil. One study (RTI
International, 2003) analyzed Cr(VI) concentrations for a limited subset of samples. All of these
samples were below the detection limit of the method. Due to the lack of data on Cr(VI), the
Agency decided to make a conservative assumption about speciation in soil. OPP adjusted the
ADDs by multiplying by 0.10 (10%) to approximate Cr(VI) speciation. This conservative
assumption most likely overestimates exposure to Cr(VI). This overestimation means that
uncertainties around the Cr(VI) values are asymmetrical; the probability that concentrations are
lower is much greater than the probability that concentrations are higher.
7-3
Migration, dispersion, dilution, retardation, degradation, and other attenuation or
transformation processes may occur over time that could change the chemical concentrations in
residues or soil. It has been conservatively assumed that the concentrations of arsenic are
relatively persistent and immobile in both media. With reference to soil, this is an important factor
to consider when evaluating the mitigation measures presented in Chapter 6.0. In calculating the
exposure doses for these mitigation conditions, SHEDS-Wood used the same soil input
distributions as were used for the baseline condition; only exposure to residue concentrations
were reduced. Conceptually, a sealant would limit the migration of CCA to surrounding soils,
however, there are no data available describing the change in soil concentrations due to the use of
sealants. Thus, the approach to estimating overall risk to surrounding soils may be conservative
(i.e., risks are overestimated).
7.3
Toxicity Data
Varying degrees of uncertainty surround the assessment of adverse health effects in
potentially exposed populations to arsenic. Some sources of uncertainty for toxic effects in
humans may include:
•
•
•
Extrapolating from a LOAEL to a NOAEL;
Extrapolation of data due to intraspecies variation; and
Extrapolation of epidemiological data from adult populations to children.
In general, cancer risk is a conservative estimate of the risk because the cancer slope
factor is characterized as a upper-bound estimate. Therefore, the true risks to humans, while not
identifiable, may likely not exceed the upper-bound estimates and in fact may be lower.
For inorganic arsenic, in this assessment, the slope factor used was 3.67 (mg/kg/day)-1.
This is the mean slope factor derived from the higher risk approach for both lung and bladder
cancers. This slope factor was used by the EPA s Office of Water when it established the MCL
for arsenic in drinking water (US EPA, 2001e). In 2001, NRC published an update to the 1999
NRC report and made some specific recommendations with respect to the EPA’s Office of Water
cancer risk estimate.
The Agency is currently considering NRC’s recommendations and their potential impact
on the cancer potency estimate. Based on the Agency’s considerations of these
recommendations, the current proposed cancer potency number may change in the final version of
this risk assessment. The slope factor published by EPA’s Integrated Risk Information System
(IRIS), 1.5 (mg/kg/day) -1 is also being revisited in FY2003 due to the recommendation by the
NRC in 2001. The uncertainties in the hazard assessment are discussed in detail in Appendix A.
7-4
For noncancer effects, OPP assessed exposure using the MOE approach. This approach
shows how many times the NOAEL or LOAEL exceed the predicted exposure. The MOE is a
ratio of the LOAEL or NOAEL to the predicted exposure, thus, the uncertainties derive from the
toxicity value and the manner in which exposure is estimated. Several conservative assumptions
are considered in setting the acceptable amount by which the predicted exposure should exceed
the LOAEL or NOAEL. Given the conservative assumptions used to generate the LOAEL and
NOAEL, it is likely that the total uncertainty of the MOE is assymetrical. There is a greater
probability that the true MOE is higher, and a lesser probability that the true MOE is lower.
7.4
Exposure Assessment
Exposure assessment is perhaps the most critical step in achieving a reliable estimate of
health risks to humans. Little direct data exist to measure arsenic and chromium exposure in
children. The exposure estimates used in this assessment were based on absorbed doses
calculated by the SHEDS-Wood model (see Zartarian et al., 2003). This model predicted
exposure and dose to arsenic and chromium using age and gender time-location-activity diaries
for children 1-6 years old. All the data from SHEDS-Wood have been either recommended from
the SAP or from the survey of studies in the EPA’s Exposure Factor’s Handbook (US EPA,
1997b). This information is used by several Agencies to estimate children’s exposure durations at
outdoor playsets and decks.
The SHEDS-Wood results showed that the significant exposure routes, in order of
descending importance, were: residue ingestion via hand-to-mouth contact, dermal residue
contact, soil ingestion, and dermal soil contact. The variability and uncertainty in the ADDs and
LADDs from SHEDS-Wood were evaluated. Sensitivity of the model to the various input
parameters was also evaluated. The following discussion summarizes these results; the full text
can be found in Zartarian et al. (2003) (see Section 5).
Variability: Generally, there were several orders of magnitude difference in absorbed dose
between the low end and high end percentiles for the various population estimates. This
was due to differences in activity patterns, soil and residue concentrations, and exposure
factors.
Uncertainty: Uncertainty was modeled using a non-parametric bootstrap approach for
ADDs. The estimated uncertainty was indicated by a factor of 3 at the median and 4 at
the 95th percentile.
Sensitivity: The most critical input variables to the model results were: wood surface
residue-to-skin transfer efficiency, deck wood surface residue concentration, fraction of
hand surface area mouthed, and hand washing events per day.
The estimated uncertainty of a factor of 3 to 4 appeared to be approximately symmetrical
around the predicted absorbed dose.
7-5
7.5
Risk Characterization
There are various sources of uncertainty in each step of the risk assessment process. In
the final estimate of risk, the uncertainty in the toxicity value is combined with the uncertainty in
the absorbed dose estimate. This combined uncertainty is greater than the uncertainty in the
exposure estimate, however, the question is - how much greater? This is not a simple question to
answer. It is beyond the scope of this risk assessment to address that question in a quantitative
manner. Thus, it is addressed in conceptual manner. Further limitations of this discussion are that
it applies to the carcinogenic risk from exposure to arsenic, as that is the most critical and it is
more appropriate to the baseline risk results (Chapter 5.0) and less so the mitigation risks
(Chapter 6.0). (This is due to the lack of any information on the uncertainty of the assumed
effectiveness of the mitigation measures.)
Uncertainty can be considered a cloud surrounding a value. If risks are presented as a
CDF, then there is a cloud surrounding the entire curve. The shape of this cloud is determined by
the uncertainty of the input variables and how these uncertainties are combined mathematically.
There are standard approaches for estimating the combined uncertainty for the simple case of two
input variables where the uncertainty of each has been quantified and it is symmetrical around the
a central value of the variable. More sophisticated approaches are required when either of the
uncertainties are asymmetrical.
In this risk assessment, only the uncertainty in the absorbed dose was characterized; the
uncertainties in the toxicity values were not characterized. To generate an uncertainty estimate for
the risk characterization, similar to the absorbed dose uncertainty estimate, would require: (1)
knowledge of the uncertainty in the slope factor and NOAEL/LOAEL, and (2) running a Monte
Carlo simulation to calculate risk that included a distribution function for the slope factor. Thus,
the uncertainty of the risk characterization step can not be quantified.
What is known about the uncertainty around the input variables is very different. The
slope factor in this assessment is not a mean value. It is at the high end of the distribution, based
on the various conservative factors that are included in the formulation of the final value (e.g., low
dose extrapolation and extrapolation from adults to children). Therefore, the “uncertainty cloud”
around the slope factor is asymmetrical. How asymmetrical is not known; however, it is likely
that the vast majority of the cloud is below the slope factor value and very little is above it. By
contrast, uncertainty in the absorbed dose estimate appears to be symmetrical based on the
analysis presented in the SHEDS-Wood report (Zartarian et al., 2003).
The uncertainty in the risk estimate is a combination of the symmetrical uncertainty in the
absorbed dose and the asymmetrical uncertainty in the slope factor. It is beyond the scope of this
assessment to mathematically combine those uncertainties. However, a relative estimate of the
shape and location of the uncertainty cloud is possible. The first order estimate is based on the
7-6
absorbed dose uncertainty. Combining the slope factor uncertainty would increase the size
(dispersion) of the cloud and shift it so that it was asymmetrical around the risk estimate (i.e.,
more of the cloud is below the risk estimate than above it).
Therefore, it is concluded that the arsenic carcinogenic risk, (especially under the assumed
mitigation measures) are conservative estimates of risk. The Cr(VI) noncancer MOEs are also
considered to be conservative (i.e., MOEs are most likely higher) due to the assumption that 10%
of total chromium was assumed to be present as Cr(VI). The noncancer arsenic MOEs are also
considered to be conservative estimates, given the assumptions for the LOAEL.
7-7
8.0 REFERENCES*
ACC, 2002. Assessment of Potential Inhalation and Dermal Exposure Associated with Pressure
Treatment of Wood with Arsenical Products. MRID 455021-01.
ACC, 2003a. CCA Workgroup, Relative Bioavailability of Dislodgeable Arsenic from CCATreated Wood, Prepared by Veterinary Medical Diagnostic Laboratory Medicine. University of
Missouri, Syracuse Research Corporation, Denver, Colorado.
ACC, 2003b. CCA Workgroup, Relative Bioavailability of Arsenic in Soil Affected by CCATreated Wood. Prepared by Veterinary Medical Diagnostic Laboratory College of Veterinary
Medicine. University of Missouri, Syracuse Research Corporation, Denver, Colorado.
APVMA, 2003. Arsenic Timber Treatments (CCA and Arsenic Trioxide) Review Scope
Document. March, 2003. http://www.apvma.gov.au/chemrev/arsenic_scope.pdf
Accessed September 17, 2003.
AWPA, 1998. Book of Standards. P5-P98 Standard for Waterbourne Preservatives.
CDHS, 1987. Condensed Report to the Legislature: Evaluation of Hazards Posed By the Use of
Wood Preservatives on Playground Equipment. State of California. Office of Environmental
Health Hazard Assessment, Department of Health Services, Health and Welfare Agency.
Cooper, P. and Y.T. Ung 1997. Effect of water repellents on leaching of CCA from treated fence
and deck units. An update presented at the 28 th Annual Meeting of the International Research
Group on Wood.
CPSC, 1990. Estimation of Hand-to-Mouth Activity by Children Based on Soil Ingestion for
Dislodgeable Arsenic Exposure Assessment. Memorandum from B. Lee to E.A. Tyrell.
CPSC, 2003a. Briefing Package. Petition to Ban Chromated Copper Arsenate (CCA)-Treated
Wood in Playground Equipment (Petition HP 01-3). February 2003.
CPSC, 2003b. Briefing Package. Staff Recommendation to Ban Use of Chromated Copper
Arsenate (CCA)-Treated Wood in Playground Equipment (Petition HP 01-3) October 2003.
Cooper, P.A., 2003. CCA Fixation and its Implications on Availability of Hexavalent Chromium
(Cr VI) for Dislodgeability and Leaching. Prepared for the American Chemistry Council
Arsenicals Wood Preservative Task Force. August 20, 2003.
8-1
DeGroot, R.C., T.W. Popham, L.R. Gjovik, and T. Forehand, 1979. Distribution Gradients of
Arsenic, Copper, and Chromium Around Preservative-treated Wooden Stakes. J. Environ. Qual.,
8(1):39-41.
Edgecomb, M, 2003. Bangor News. Legislators Ban Lumber Treated With Arsenic. June 4,2003.
http://www.bangornews.com/editorialnews/article.cfm/ID/402406/cfid/9206765/cftoken/3105964
Accessed September 17, 2003.
EMRA, 2003a. Report on Copper, Chromium and Arsenic (CCA) Treated Timber. Report
prepared by Deborah Read, Public Health Physician, EMRA. April. ISBN 0-478-21521-5.
EMRA, 2003b. Copper Chromium Arsenic (CCA) Treatment of Timber. Report from the
Environmental Risk Management Authority. Niel Walter, Chair. May.
Environmental Health Perspectives, 2001. Volume 109, Number 6, June 2001.
http:\\Ehpnet1.niehs.nih.gov/docs/2001/109-6/focus.pdf. Accessed September 18, 2003.
Franzblau, A. and Lilis, R., 1989. Acute Arsenic Intoxication from Environmental Arsenic
Exposure. Archives of Envir. Health 44(6). 385-390.
Ginsberg, G., 2003. Assessing Cancer Risks from Short-term Exposures in Children. Risk
Analysis, Vol 23, No. 1. Society for Risk Analysis.
Healthy Schools Network, 2003. The Guide to Playgrounds and Arsenic Wood. Undated
http://www.healthyschools.or/documents/CCA_Guide.pdf
Accessed September 15, 2003.
Hopenhayn,C.; Ferreccio, C.; Browning, S.R.; Huang, B. Peralta, C.; Gibb, H.; and HertzPicciotto, I. 2003. Arsenic Exposure from Drinking Water and Birth Weight. Epidemiology.
14:593-602.
Kartal, S. and Lebow, S., 2000. Effect of Compression Wood on Leaching of Chromium, Copper,
and Arsenic From CCA-C Treated Red Pine (Pinus resinosa Ait.) USDA Forest Service, Forest
Products Laboratory, Madison, WI, USA.
8-2
Lebow, S., 1996. Leaching of Wood Preservative Components and their Mobility in the
Environment- Summary of Pertinent Literature. Gen. Tech. Rep. FPL-GTR-93. Madison,
WI: U.S. Department of Agriculture, Forest Service, Forest Products Laboratory, 36 p.
McMahon and Chen, 2003. Hazard Identification and Toxicology Endpoint Selection for
Inorganic Arsenic and Inorganic Chromium. Prepared by the Office of Pesticide Programs
Antimicrobial Division. Draft Version, November 4, 2003.
Mizuta, N, Mizuta, et al., 1956. An Outbreak of Acute Arsenic Poisoning Caused by ArsenicContaining Soy-Sauce (Shoyu). A Clinical Report of 220 Cases. Bull Yamaguchi Med
Sch 4(2-3):131-149.
Nico, P., Fendorf, S., Lownery, Y., Holm, S. and Ruby, M., 2003. Chemical Structure of Arsenic
and Chromium in CCA-Treated Wood: Implications of Environmental Weathering. Draft Version
August 2003, Unpublished.
NRC (National Research Council), 2001. Arsenic in Drinking Water. 2001 update. National
Academy Press, Washington, D.C.
NRC (National Research Council), 1999. Arsenic in Drinking Water. National Academy Press,
Washington, D.C.
Osmose, 2000. Metal Removal from CCA-treated Lumber Under Simulated Normal Use
Conditions. Osmose Research Division. Osmose Wood Preserving Company. Buffalo, New
York.
Our Stolen Future, 2003. Arsenic Treated Wood Banned in Maine. June 4, 2003.
http://www.ourstolenfuture.org/Commentary/News/2003/2003-0604-BDN-arsenicban.htm.
Accessed September 15, 2003.
Personal Communication, 2003. Email from Cathy Campbell, PMRA to Winston Dang, U.S.EPA.
9/16/2003. Re: Canada’s Action on CCA.
PMRA, 2003. Re-evaluation Note- Chormated Copper Arsenate (CCA). April 3, 2002.
http://www.hc-sc.gc.ca/pmra-arla/english/pdf/rev/rev2002-030e.pdf
Accessed on September 17, 2003.
Riedel, D., D. Galarneau, J. Harrison, D.C. Gregoire and N. Bertrand. February, 1991.
Residues of Arsenic, Chromium and Copper On and Near Playground Structures Built of Wood
Pressure-treated with CCA Type Preservatives. Health and Welfare Canada. (Unpublished).
8-3
RTI International, 2003. Assessment of Exposure to Metals in CCA-Preserved Wood: Full
Study. Prepared for American Chemistry Council CCA Task Force. Prepared by RTI
International. Research Triangle Park, North Carolina. June 20, 2003. (This reference is same as
ACC 2003a in SHEDS-Wood document)
Spease, 2002. CA Playground Safety Regulation. July 13, 2002.
http://www.spease.com/Wood%20Preservatives.html. Accessed September 15, 2003.
Stilwell, DE and Gorny, KD, 1997. Contamination of Soil with Copper, Chromium, and Arsenic
Under Decks Built from Pressure Treated Wood. Bulletin of Environmental Contamination and
Toxicology 58:22-29. Springer Verlag New York, Inc.
Stilwell, D., 1998. Arsenic From CCA-treated Wood Can be Reduced by Coating. Frontiers of
Plant Science 51(1):6-8.
Townsend, T.G., K. Stook, T.M. Tolaymat, J.K. Song, H. Solo-Gabriele, N. Hosein, and B.
Khan, 2001. New lines of CCA-treated wood research: In-service and disposal issues - Final
Technical Report #00-12. Submitted to the Florida Center for Solid and Hazardous Waste,
Gainesville, Florida.
Tyl, R.W., Marr, M., and Meyers, C.B., 1991. Developmental Toxicity Evaluation of Chromic
Acid Administered by Gavage to New Zealand White Rabbits. Research Triangle Institute,
Reserch Triangle Park, NC Study No. 60C-4808-30/40. Unpublished.
U.S. EPA, 2003a. Draft Final Guidelines for Carcinogenic Risk Assessment. Risk Assessment
Forum. National Center for Environmental Assessment. Washington D.C. EPA/630/P-03/001A.
U.S. EPA, 2003b. Supplemental Guidance for Assessing Cancer Susceptibility from Early-Life
Exposure to Carcinogens. Risk Assessment Forum. National Center for Environmental
Assessment. Washington D.C. EPA/630/R-03/003.
U.S. EPA, 2001a. An Evaluation of the Non-Dietary Exposures and Risks to Children from
Contact with CCA-Treated Wood Playground Structures and CCA-Contaminated Soil (Internal
Draft Only). Prepared by the Office of Pesticide Programs Antimicrobial Division. Internal Draft
Version, May 30, 2001.
U.S. EPA, 2001b. Children’s Exposure to CCA-Treated Wood Playground Equipment and CCAContaminated Soil (Final Report to SAP 9/27/01). Prepared by the Office of Pesticide Programs
Antimicrobial Division. Draft Version, September 27, 2001.
8-4
U.S. EPA, 2001c. Memorandum: Transmittal of the Final Report for the FIFRA Scientific
Advisory Panel (SAP) Meeting Held October 23-25, 2001. From Olga Odiott and Larry Dorsey,
Office of Science Coordination and Policy to Marcia Mulkey, Director Office of Pesticide
Programs. October 25, 2001.
U.S. EPA, 2001d. Process for Conducting Probabilistic Risk Assessment. Risk Assessment
Guidance for Superfund. Volume 3. Part A. December 31, 2001.
U.S. EPA, 2001e. National Primary Drinking Water Regulations: Arsenic and Clarifications to
Compliance and New Source Contaminants Monitoring; Final Rule. 40CFR Parts 9, 141, and
142. EPA-815-Z-01-001.
U.S. EPA, 1990. National Oil and Hazardous Substances Pollution Contingency Plan. Final
Rule. 40 CFR 300: 55 Federal Register, 8666-8865, March 8.
U.S. EPA, 1998a. Guidance for Submission of Probabilistic Exposure Assessments to the Office
of Pesticide Programs' Health Effects Division. Prepared by the Office of Pesticide Programs
Health Effects Division. Draft Version, February 6, 1998.
U.S. EPA 1998b. IRIS, Chromium (VI), 1998; CASRN 18540-29-9, September 3, 1998.
U.S. EPA, 1997a. Policy for Use of Probabilistic Analysis in Risk Assessment. Prepared by the
Science Policy Council. http://epa.gov/esp/osp/spc/probpd.htm.
U.S. EPA, 1997b. Exposure Factors Handbook. Volume I. Prepared by the Office of Research
and Development. Washington D.C., 20460. EPA/600/P-95/002Fa.
Waalkes, M.P.; Ward, J.M.; Liu, J. and Diwan, B.A. 2003. Transplacental carcinogenicity of
inorganic arsenic in the drinking water: induction of hepatic, ovarian, pulmonary, and adrenal
tumors in mice. Toxicology and Applied Pharmacology: 186:7-17
Wester, R.C., Hui, X., Barbadillo, S., Maibach, MI., Lowney, Y.W., Schoof, R.A., Holm, S.E.,
and Ruby, M.V., 2003. In Vivo Percutaneous Absorption of Arsenic from Water and CCAtreated Wood Residue Draft. August 2003.
Wester, R.C., Maibach, H.I., Sedik, L. Melendres, J., and Wader, M., 1993. In Vivo and in Vitro
Percutaneous Absorption and Skin Decontamination of Arsenic From Water and Soil.
Fundamental and Applied Toxicology 20:336-340
8-5
Waalkes, M.P.; Ward, J.M.; Liu, J. and Diwan, B.A. 2003. Transplacental carcinogenicity of
inorganic arsenic in the drinking water: induction of hepatic, ovarian, pulmonary, and adrenal
tumors in mice. Toxicology and Applied Pharmacology: 186:7-17
Zartarian, V.G., Xue, J., Özkaynak, H., Dang, W., Glen, G. and Stallings C., 2003. A
Probabilistic Exposure Assessment for Children Who Contact CCA-Treated Playsets and Decks
Using the Stochastic Human Exposure and Dose Simulation Model for the Wood Preservative
Exposure Scenario (SHEDS-Wood). Prepared by Office of Research and Development, National
Exposure Research Laboratory and Office of Pesticide Programs, Antimicrobial Division. Draft
Report September 25, 2003.
*Additional references used to develop exposures and toxicity can be found in Zartarian et al.
(2003) and Appendix A, respectively.
8-6
APPENDICES
A Probabilistic Exposure and Risk Assessment for Children Who
Contact CCA-Treated Playsets and Decks
Draft Final Report
November 10, 2003
Prepared by
U. S. Environmental Protection Agency
Office of Pesticide Programs, Antimicrobials Division
and
Office of Research and Development
National Exposure Research Laboratory
DISCLAIMER
This report has undergone internal EPA review through the Office of Research and Development (ORD) and the
Office of Pesticide Programs (OPP). It is currently undergoing additional external review through OPP. Thus, this
report should not be considered final until it has been submitted to OPP's Scientific Advisory Panel. Some of the
statutory provisions described in this report contain legally binding requirements. However, this report does not
substitute for those provisions or regulations, nor is it regulation itself. Any decisions regarding a particular risk
reduction process and remedy selection decision will be made based on the statute and regulation, and EPA
decision makers retain the discretion to adopt approaches on a case-by-case basis.
Appendix A
Hazard Identification and Toxicology Endpoint Selection for
Inorganic Arsenic and Inorganic Chromium
November 10, 2003
Hazard Identification and Toxicology Endpoint Selection for
Inorganic Arsenic and Inorganic Chromium
November 10, 2003
Timothy F. McMahon, Ph.D. and Jonathan Chen, Ph.D.
U.S. Environmental Protection Agency
Office of Pesticide Programs
Antimicrobials Division
1
TABLE OF CONTENTS
0.0
INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 3
1.0
HAZARD CHARACTERIZATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
1.1
Hazard Characterization - Arsenic . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
1.1.1 Acute Toxicity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 4
1.1.2 Non-Acute Toxicity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
1.1.3 Metabolism . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 9
1.2
Hazard Characterization - Chromiu m . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
1.2.1 Acute Toxicity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
1.2.2 Non-Acute Toxicity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
1.2.3 Metabolism . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 19
2.0
DOSE-RESPONSE ASSESSMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
2.1
Inorganic Arsenic-Endpoint Selectio n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
2.1.1 Acute Reference Dose (RfD) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
2.1.2 Chronic Reference Dose (RfD) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
2.1.3 Short (1-30 days ) and Intermediate (30-180 days) Incidental Oral
Exposure
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...
2.1.4 Dermal Absorption . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
2.1.5 Short (1-30 days ) and Intermediate (30-180 days) Dermal Exposure
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...
2.1.6 Long-Term Dermal Exposure . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
2.1.7 Short-, Intermediate-, and Long-term Inhalation Exposure
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...
2.1.8 Carcinogenicity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
2.2
Inorganic Chromium Endpoint Selection
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. .
2.2.1 Acute Reference Dose (RfD) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
2.2.2 Chronic Reference Dose (RfD) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
2.2.3 Short-Term (1-30 days) and Intemediate-Term (30-180 days) Incidental
Oral Exposure
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...
2.2.4 Dermal Absorption . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
2.2.5 Short-, Intermediate-, and Long- term Dermal Exposure
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...
2.2.6 Inhalation Exposure (all durations) . . . . . . . . . . . . . . . . . . . . . . . . . . ..
2.2.7 Carcinogenicity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
3.0
20
22
22
22
24
24
25
25
25
26
31
31
31
31
32
33
33
34
REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 36
2
0.0
INTRODUCTION
The Agency has become aware in recent years of concerns raised by the public regarding the
potential hazards associated with the continued use of CCA-treated lumber, especially the use of
this material in playground equipment to which infants and children may be exposed through
direct dermal contact with the treated wood and/or soil around the treated wood structure, or
through oral ingestion of chemical residue from touching of wood and/or soil and subsequent
hand-to-mouth behaviors. As a result of these concerns, the Agency has embarked upon a process
to assess the exposures and risks associated with the current uses of CCA-treated lumber,
including exposures and risks associated with use of this wood in playground structures. In any
such assessment, the toxicity of the pesticide chemical must first be adequately described, either
through submission of guideline toxicology studies that are reviewed by the Agency, or through
citation of scientific studies in the peer-reviewed literature. For the present assessment, the
Agency recognizes that inorganic arsenic and inorganic chromium are the compounds of
toxicological concern with respect to exposure to CCA-treated wood. The following sections
characterize the hazards of inorganic arsenic and inorganic chromium. Information was
summarized from submitted toxicology studies, the open scientific literature, and from published
documents by the USEPA and the Agency for Toxic Substances and Disease Registry (ATSDR).
It is noted for inorganic arsenic that in most cases, human data (in the form of epidemiology
studies and case reports) provide the basis for the hazard identification, as most laboratory animal
models appear to be substantially less susceptible to arsenic toxicity than humans.
For chromium, hazard data show clearly that Cr(VI) demonstrates more significant toxicity than
Cr (III). The Agency has not identified any endpoints of concern for Cr(III). For exposure to
Cr(VI), the Agency has identified toxicological endpoints of concern and has used these endpoints
in conjunction with exposure to Cr(VI) for evaluating risks associated with Cr (VI).
Copper as a component of CCA-treated wood is not considered in this document. Copper is an
essential nutrient which functions as a component of several enzymes in humans, and toxicity of
copper in humans involves consumption of water contaminated with high levels of copper, suicide
attempts using copper sulfate, or genetic disorders such as Wilson’s disease.
3
1.0
HAZARD CHARACTERIZATION
1.1
Hazard Characterization - Arsenic
Arsenic is a naturally occurring element present in soil, water, and food. In the environment,
arsenic exists in many different forms. In water, for example, arsenic exists primarily as the
inorganic forms As +3 (arsenite) and As +5 (arsenate), while in food, arsenic exists primarily in
organic forms (seafood, for example, contains arsenic as arsenobetaine, a form which is absorbed
but rapidly excreted unchanged). Human activities also result in the release of arsenic into the
environment, such as residual arsenic from former pesticidal use, smelter emissions, and the use
of chromated copper arsenicals (CCA) in the pressure-treatment of wood for construction of
decks, fences, playgrounds, and other structural uses.
Inorganic arsenic, prior to 1991, was used as an agricultural pesticide. In 1991, the Agency
proposed cancellation of the sole remaining agricultural use of arsenic acid (As+5) on cotton.
Subsequently, this registration was voluntarily canceled by the sponsor and made immediately
effective by the Agency (Federal Register, 1993). However, inorganic arsenic contained within
CCA-treated wood continues to be widely used for decking and fencing lumber as well as
playground equipment.
1.1.1 Acute Toxicity
The acute toxicity summary of inorganic arsenic (arsenic acid 7.5%) is summarized in Table 1.
Humans are very sensitive to arsenic toxicity when compared with other experimental animals.
Inorganic arsenic is acutely toxic, and ingestion of large doses leads to gastrointestinal symptoms,
disturbances of cardiovascular and nervous system functions, and eventually death. The effects
seen after short-term arsenic exposure (appearance of edema, gastrointestinal or upper respiratory
symptoms) differ from those after longer exposure (symptoms of skin and neuropathy). Some of
the effects after short-term exposure tended to subside gradually from the 5th day of the illness,
despite continuous intakes of the poison. In contrast, symptoms of peripheral neuropathy
appeared in some individuals even after the cessation of arsenical intakes
The acute oral toxicity of inorganic arsenic in humans shows lethal effects in the range of 22-121
mg/kg, which is consistent with results of animal studies showing lethality in the range of 15-175
mg/kg. There are no studies reporting death in humans after dermal exposure to inorganic
arsenic, which is consistent with results of animals studies showing no mortality at dermal doses
up to 1000 mg/kg. Mortality in humans from short-term inhalation exposure to inorganic arsenic
has not been observed in occupational settings at air levels up to 100 mg/m3. One study in
pregnant rats reported lethality of inorganic arsenic at a concentration of 20 mg/m 3. Arsenic has
been shown to result in contact dermatitis in humans exposed occupationally, and animal studies
are also suggestive of mild to severe dermal irritation after application of arsenic to skin. Severe
ocular irritation was observed in an acute eye irritation study (MRID # 00026356). Arsenic does
not produce skin sensitization in a guinea pig model (MRID # 40646201).
4
1.1.2 Non-Acute Toxicity
Subchronic studies with arsenic in experimental animal models have produced only generalized
toxicity, i.e., weight loss, and decreased survival, while data from human exposures have shown
more specific toxic effects, such as neurotoxicity and hyperkeratoses of the skin of the hands and
feet (ATSDR, 2000a).
Chronic toxicity studies with inorganic arsenic in experimental animals also show a lack of specific
toxic effects, whereas the scientific literature that describes chronic human exposure shows a clear
relationship between chronic exposure to inorganic arsenic and the development of skin cancer as
well as cancers of the lung, liver, and bladder (ATSDR, 2000; NRC, 1999).
The most notable example of this is the data of Tseng, (1968, 1977) who conducted
epidemiological studies of chronic oral exposure of humans to arsenic contained in food and
water. From these studies it was noted that hyperpigmentation, keratosis and possible vascular
complications [Blackfoot disease] occurred at a dose of 0.17 mg arsenic per liter of water,
equivalent of 0.014 mg/kg/ day. Several follow-up studies of the Taiwanese population exposed
to inorganic arsenic in drinking water showed an increase in fatal internal organ cancers as well as
an increase in skin cancer. Other investigators found that the standard mortality ratios (SMR) and
cumulative mortality rates for cancers of the bladder, kidney, skin, lung, and liver were
significantly greater in the Blackfoot disease endemic area of Taiwan when compared with the age
adjusted rates for the general population of Taiwan.
Data on the developmental and reproductive toxicity of inorganic arsenic in humans is not
extensive. One study conducted in Sweden among copper smelter workers showed significantly
reduced live birth weights in offspring of women employed at the copper smelter and increased
incidence of spontaneous abortion among those who worked at the smelter or lived i nproximity
to it. However, effects from exposure to lead or copper in this study could not be ruled out.
Hopenhayn-Rich (2000) conducted a retrospective study of late fetal, neonatal and postnatal
mortality in Antofagasta, Chile for the years 1950 to 1996. The data from this study indicated an
elevation in late fetal, neonatal and postnatal mortality compared to a comparison group in
Valparaiso, Chile during the period when drinking water in Antofagasta was contaminated [860
ug/L] with arsenic (1958 to 1970). There was a decline in late fetal, neonatal and postnatal
mortality when the concentration of arsenic in the drinking water declined due to installation of a
water treatment plant. After installation of the plant, the mortality rates in Antofagasta were
indistinguishable from those in Valparaiso. It was noted that the mothers involved in this incident
had characteristic arsenic-induced skin lesions. A prospective cohort study was conducted in these
two cities during the period in the period when drinking water arsenic levels in Antofagasta is
40µg/L and in Valparaiso is less than 1µg/L. By comparing the preganancy and birth
5
Table 1.
Acute Toxicity Summary of Arsenic Acid (75%)
Guideline
Reference No.
Study Type
MRID/
Data Accession No.
81-1
Acute Oral
404090-01
Results
Mouse
LD50
(OPPTS 870.1100)
M+F
26356
Rat
LD50
M+F
81-2
Acute Dermal
26356
Rabbit
LD50
(OPPTS 870.1200)
81-3
Acute Inhalation
404639-02
Mouse
LC50
(OPPTS 870.1300)
M+F
81-4
I
II
= ? 1750 mg/kg
= ? 2300 mg/kg
= ? 1.153 mg/L
= ? 0.79 mg/L
= 1.040 mg/L
II
26356
Rabbit
3/6 animals died by day 7. The 3
surviving animals were
sacrificed on day 9 because of
severe ocular irritation and
corrosion.
I
Primary Skin
Irritation
26356
Rabbit
At 30 minutes, all animals
showed moderate to severe
erythema and slight to severe
edema. All animals died prior to
the 24 hour observation.
I
Dermal
Sensitization
406462-01
(OPPTS 870.2500)
81-6
= ? 76 mg/kg
= ? 37 mg/kg
= 52 mg/kg
II
Primary Eye
Irritation
(OPPTS 870.2400)
81-5
= ? 141 mg/kg
= ? 160 mg/kg
= 150 mg/kg
Toxicity
Category
(OPPTS 870.2600)
6
Guinea Pig
Not a Sensitizer
information form these two cities, the results suggests that moderate arsenic exposure (<50µg/L)
durign preganancy may associated with reduction in birth weight (Hopenhayn et al., 2003).
In laboratory animals, the major teratogenic effect induced by inorganic arsenic is neural tube
defect, characterized by exencephaly and encephalocele. However, this effect has not been
observed in humans (IPCS, 2001). In addition, data on the developmental and reproductive
toxicity of inorganic arsenic submitted to the Agency show effects on offspring only at doses that
are maternally toxic.
In a developmental toxicity study (Nemac, 1968b), pregnant Crl:CD-1(ICR)BR mice (25 per dose
group) received a single daily gavage of aqueous Arsenic Acid (75%) from day 6 through 15 of
gestation. Doses were 0, 10, 32 and 64 mg/kg/day. Controls received deionized water. Body
weights were recorded at six hour periods. Cesarean section was on day 18. Fetuses were
weighed, sexed and examined for external skeletal and soft tissue malformations and variations.
At the high dose, two dams died. Signs included lethargy, decreased urination and defecation, soft
stool or mucoid feces. Brown urogenital matting, and red material around the eyes. Necropsy
showed bilateral reddening of cortico-medullary junction (kidneys) and a red areas in the
stomach. At mid and (especially) top dose, the dams showed weight loss and an elevated
incidence of total litter resorption. An increase in exencephaly occurred in the both the low
(1/231 fetuses per 1 litter) and the high (2/146 fetuses per 1 litter) doses, but statistical
significance was not seen. The Maternal Toxicity NOAEL was determined to be 32 mg/kg/day,
and the Maternal toxicity LOAEL was determined to be 64 mg/kg/day, based on increased total
litter resorption, reduced body weight, and increased maternal mortality. The Developmental
Toxicity NOAEL was determined to be 32 mg/kg/day and the Developmental Toxicity LOAEL
was determined to be 64 mg/kg/day, based on reduced mean viable fetuses, reduced fetal weights,
increased post implantation loss and increased incidence of exencephaly (not statistically
significant).
In a prenatal developmental toxicity study (Nemec, 1988a), artificially inseminated New Zealand
White rabbits (20/dose) received aqueous arsenic acid (75%) by gavage from days 6 through 18
of gestation inclusive at doses of 0, 0.25, 1, and 4 mg/kg/ day. At the 4 mg/kg/day dose level,
seven dams died or were sacrificed in extremis. Reduced body weight gain, clinical signs of
toxicity (prostration, ataxia, decreased defacation and urination, mucoid feces), and histo-logical
alterations in dams sacrificed or dead at the high dose (pale, soft, or mottled kidneys; pale and soft
liver; dark red areas of the stomach; dark red lungs) were observed. Fetal data showed increased
post-implantation loss at the 4 mg/kg/day dose (1.8 vs. 0.5 in control) and reduced mean viable
fetuses (4.9 vs. 6.7 in control). There was no evidence from the data of increased incidence of
fetal alterations (variations, malformations) related to treatment with test article. The Maternal
NOAEL was determined to be 1 mg/kg/day, and the Maternal LOAEL was determined to be 4
mg/kg/day, based on increased mortality, decreased body weight gain, clinical signs, and
histological alterations of the kidney and liver. The Developmental NOAEL was determined to be
1 mg/kg/day, and the Developmental LOAEL was determined to be 4 mg/kg/day, based on
increased post-implantation loss and decreased viable fetuses.
7
With regard to the susceptibility of offspring to the toxicity of inorganic arsenic, DeSesso, (1998)
in a review paper exploring the reproductive and developmental toxicity of arsenic acid (As+5)
noted that in three repeated oral dose studies carried out under EPA guidelines for assaying
developmental toxicity, arsenic acid was not teratogenic in: mice by oral gavage (10 to 64
mg/kg/day), rabbits by oral gavage (1 to 4 mg/kg/day) and in a mouse two-generation feeding
study (20 to 500 ppm). Other animal developmental and reproductive toxicity data based on the
published literature also showed no increased sensitivity to arsenic (+5) when given orally by
repeated doses.
In a tranplacental carcinoginicity study (Waalkes et al., 2003), pregnant C3H mice were given
drinking water containing sodium arsenic at 0, 42,5 and 85 ppm ad libitum from day 8 to 18 of
gestation. These dosages were well tolerated and did not decrease the body weight of the dams
during gestation and the birth weight of the offspring after birth. However, after weaning at 4
weeks, the offsprings were put into separate gender-base groups according to maternal exposure
level. The offspring received no additional arsenic treatment. The study lasted 74 weeks in males
and 90 weeks in females. A complete necropsy was performed on all mice and tissues were
examined. In male, there was a dose-related increases in the incidences of heptatocellular
carcinoma, liver tumor, adrenal tumor. In females offsprin, dose-related increases occurred in
ovarian tumors incidence and lung carcinoma incidence were observed.(Waalkes et al., 2003)
The same authors note that “there is a paucity of human data regarding inorganic arsenic exposure
during pregnancy and potential adverse effects on progeny. The available epidemiological studies
were neither rigorously designed nor well controlled. These studies failed to find a definitive or
consistent association between arsenic exposure and adverse pregnancy outcome. Consequently,
claims of potential adverse effects of inorganic arsenic on human development remain
unsubstantiated.” This conclusion is consistent with ATSDR (2000a), which noted that
“Although several studies have reported marginal associations between prolonged low-dose
human arsenic exposure and adverse reproductive outcomes, including spontaneous abortion,
stillbirth, developmental impairment, and congenital malformation, none of these studies have
provided convincing evidence for such effects. “
The January 22, 2001 Federal Register Notice (Vol. 66, No. 14, pages 7027-7028), in which the
arsenic drinking water standard was discussed in relation to susceptibility of certain human
subpopulations including infants and children also supports the view that inorganic arsenic does
not pose a special sensitivity to children. In that notice, the Agency agreed with a report by the
National Research Council noting “that there is a marked variation in susceptibility to arsenicinduced toxic effects which may be influenced by factors such as genetic polymorphisms, life stage
at which exposures occur, sex, nutritional status, and concurrent exposures to other agents or
environmental factors.” However, the view was also shared between the EPA and NRC that
“there is insufficient scientific information to permit separate cancer risk estimates for potential
subpopulations...and that factors that influence sensitivity to or expression of arsenic-associated
cancer and non-cancer effects need to be better characterized. The EPA agrees with the NRC
that there is not enough information to make risk conclusions regarding any specific
8
subpopulations.” In the latest update to this issue (NRC, 2001), it is noted that while “evidence
from human studies suggests the potential for adverse effects on several reproductive endpoints...
“there are no reliable data that indicate heightened susceptibility of children to arsenic.”
Neurotoxicity of inorganic arsenic is not evident in studies with experimental animals. However,
there is a large body of epidemiology studies and case reports which describe neurotoxicity in
humans after both acute and chronic exposures, characterized by headache, lethargy, seizures,
coma, encephalopathy (after acute exposures of 2 mg/kg/day and above), and peripheral
neuropathy (after repeated exposures to 0.03-0.1 mg/kg/day) (ATSDR, 2000a).
Mutagenicity studies using inorganic arsenic have shown mixed results. Sodium arsenite is not
genotoxic to Chinese hamster ovary (CHO) cells (Rossman et al., 1980) or Syrian hamster
embryo cells (Lee et al., 1985b) when selecting for ouabain- (ATPase) or thioguanine-resistant
(hypoxanthine phosphoribosyl transferase, HPRT) mutants. In the L5178Y mouse lymphoma
assay, sodium arsenite is weakly genotoxic at the thymidine kinase locus without metabolic
activation (Oberly et al., 1982; Moore et al., 1997a). Sodium arsenate is even a weaker mutagen
with (Oberly et al., 1982) and without metabolic activation (Moore et al., 1997a). The type of
effects reported by Moore et al. (1997a) were chromosomal aberrations, micronuclei (arsenite
only) polyploidy and endoreduplication.
Sodium arsenate and sodium arsenite induce sister chromatid exchanges and chromosomal
aberrations in hamster embryo cells (10-7mol/litre-10-4mol/litre) (Larramendy et al., 1981; Lee et
al., 1985b; Kochhar et al., 1996). The aberrations are characterized by chromatid gaps, breaks,
and fragmentation, endoreduplication and chromosomal breaks. These clastogenic effects are
observed at lower doses of arsenite than arsenate. The difference may be due to greater in vitro
cellular uptake of arsenite than arsenate (Lerman et al., 1983; Bertolero et al., 1987). GaAs (2.510 µg/ml) did not induce micronuclei in Syrian hamster embryo cells (Gibson et al., 1997).
Recently, methylated trivalent forms of arsenic have been shown to nick and/or completely
degrade f X174 DNA in vitro (Mass et al., 2001), while sodium arsenite, arsenate, and the
pentavalent methylated forms of arsenic were without effect. In the single-cell gel assay (COMET
assay)using human lymphocytes, inorganic arsenite and arsenate produced concentrationdependent linear increases in DNA damage, but the methylated trivalent forms of arsenic were
observed to be 54-77 times more potent in this assay than the non-methylated forms. DNA
damage occurred in the absence of metabolic activation in both assays.
1.1.3 Metabolism
Metabolism of inorganic arsenic first proceeds through non-enzymatic reduction of arsenate to
arsenite, which can then undergo enzymatic methylation to the products monomethylarsinic acid
and dimethylarsinic acid. These products are then reduced to the monomethylarsinous acid and
dimethylarsinous acid produts. The major site of methylation appears to be liver, where the
methylation reaction is mediated by methyltransferase enzymes using S-adenylmethionine as a
9
cosubstrate. The products of inorganic arsenic metabolism in urine have been identified as As(+3),
As(+5), monomethylarsinous acid, and dimethylarsinous acid. Urinary products appear similar
among species studied (ATSDR, 2000a), but the relative proportions of these products vary
greatly.
1.2
Hazard Characterization - Chromium
Chromium is a naturally occurring element found in animals, plants, rocks, in soil, and in volcanic
dust and gases. In the trivalent (+3) state, chromium compounds are stable and occur in nature in
this state in ores such as ferrochromite. Chromium (VI) is second-most stable relative to the (+3)
form, but rarely occurs naturally and is usually produced from anthropogenic sources (ATSDR,
2000b). The general population is exposed to chromium by inhalation of ambient air, ingestion of
food, and drinking of water. Dermal contact with chromium can also occur from skin contact
with products containing chromium or from soils containing chromium.
In humans and animals, chromium (III) is an essential nutrient that plays a role in glucose, fat, and
protein metabolism. The biologically active form of chromium exists as a complex of chromium
(III), nicotninc acid, and possibly the amino acids glycine, cysteine, and glutamic acid to form
glucose tolerance factor. GTF is believed to function by facilitating the interaction of insulin with
its cellular receptor sites although the exact mechanism is not known. The National Research
Council recommends a dietary intake of 50-200 micrograms per day for chromium III.
Chromium in the ambient air occurs from natural sources, industrial and product uses,
and burning of fossil fuels and wood. The most important industrial sources of chromium in the
atmosphere originate from ferrochrome production. Ore refining, chemical and refractory
processing, cement-producing plants, automobile brake lining and catalytic converters for
automobiles, leather tanneries, and chrome pigments also contribute to the atmospheric burden of
chromium (Fishbein, 1981). Chromate chemicals used as mist inhibitors in cooling towers and
the mist formed during chrome plating are probably the primary sources of Cr(VI) emitted as
mists in the atmosphere (Towill et al., 1978).
Surface runoff, deposition from air, and release of municipal and industrial waste waters
are the sources of chromium in surface waters.
Ingested hexavalent chromium is efficiently reduced to the trivalent form in the gastrointestinal
tract (DeFlora et al., 1987). In the lungs, hexavalent chromium can be reduced to the trivalent
form by ascorbate and glutathione. Given the rapid reduction of Cr(VI) to Cr(III) in vivo, it is
relevant to consider whether environmental exposures to Cr(VI) or administration of Cr(VI) in
controlled animal experiments is essentially identical to environmental exposures to Cr(III) or
administration of Cr(III) in controlled experiments. For chromium, hazard data show clearly that
Cr (VI) demonstrates more significant toxicity than Cr (III). The Agency has not identified any
endpoints of concern for Cr(III). For exposure to Cr(VI), the Agency has identified toxicological
endpoints of concern and has used these endpoints in conjunction with exposure to Cr(VI) for
10
evaluating risks associated with Cr (VI).
1.2.1 Acute Toxicity
The acute toxicity summary of the Chromium (VI) is summarized in Table 2. In acute toxicity animal
studies, administration of chromium (VI) (as chromic acid) by the oral, dermal, and inhalation
routes resulted in significant acute toxicity as measured by lethality. The measured oral LD50 in
rats was reported as 52 mg/kg, the dermal LD50 as 57 mg/kg, and the inhalation LC50 as 0.217
mg/L, placing chromium (VI) in Toxicity Category I for acute lethality. Human reports of death
after ingestion of chromium show lethality at similar dose levels (ATSDR, 1998). Chromium (VI)
is a significant eye and skin irritant, and severe allergic reactions consisting of redness and
swelling of the skin have also been noted in exposed animals and humans. Case reports of humans
who have intentionally or accidentally ingested chromium have also shown severe respiratory
effects (pulmonary edema, bronchitis, bronchopneumonia), cardiovascular effects (cardiac arrest),
and gastrointestinal effects (hemorrhage, ulceration).
In contrast to the acute toxicity of chromium (VI), acute toxicity data for chromium (III) show
less severe acute toxicity, with oral LD50 values in rats reported as 183-200 mg/kg or 2365
mg/kg. There are no reports of lethality in experimental animals after acute inhalation or acute
dermal exposure to chromium (III). However, skin irritation and sensitization have also been
observed from exposure to chromium (III).
The dermal irritancy and sensitization potential of chromium compounds are worthy of note. The
potent skin allergenicity of chromium has been well documented in the literature, and chromium
compounds have been reported to be the most frequent sensitizing agents in man (IRIS, 2000).
The prevalence of Cr(VI) sensitivity among the general U.S. population is estimated to be 0.08%,
based on studies conducted by Proctor et al (1998). Most of the occurrences of contact dermatitis
and sensitization cited are from the result of occupational exposures, but include the wood
preserving industry (Burrows, 1983). For previously sensitized individuals, very low dosage of
Cr(VI) can elicit allergic contact dermatitis. Several studies document the sensitization reactions
11
Table 2:
Acute Toxicity Summary of the Chromium (VI)
Toxicity
Category
Guideline
Study Type
[Substance]
MRID/Literature
Results
81-1
Acute Oral/Rat
434294-01
I
(OPPTS
870.1100)
[Chromic Acid,
100% a.i.]
LD50 = ? 56 mg/kg
= ? 48 mg/kg
M+F = 52 mg/kg
81-2
Acute
Dermal/Rabbit
434294-02
LD50 = ? >48 mg/kg
= ? 48 mg/kg
I
(OPPTS
870.1200)
81-3
(OPPTS
870.1300)
81-4
(OPPTS
870.2400)
81-5
(OPPTS
870.2500)
81-6
(OPPTS
870.2600)
[Chromic Acid,
100% a.i.]
Acute
Inhalation/Rat
M+F = 57 mg/kg
434294-03
LC50 = ? 0.263 mg/L
= ? 0.167 mg/L
M+F = 0.217 mg/L
I
Waiver
I
[Chromic Acid,
100% a.i.]
Primary Eye
Irritation
Literature
Corrosive
[Various Cr(VI)
compounds]
Primary Dermal
Irritation
Literature
Waiver
Corrosive
[Various Cr(VI)
compounds]
Dermal
Sensitization
/Guinea Pig
Literature
[Various Cr(VI)
compounds]
12
Strong sensitizer
I
observed in humans previously exposed dermally to chromium (VI) compounds. Sensitization
can also be observed in humans with chromium (III) if exposure concentration is high enough
(ATSDR, 2000b). Bagdon (1991) collected skin hypersensitivity data for trivalent chromium
compounds in human subjects and concluded that the threshold level for evoking hypersensitivity
reactions from trivalent chromium compounds is approximately 50-fold higher than for hexavalent
chromium compounds.
Experimental animal models also show that sensitization to chromium compounds can occur, and
in some cases, the sensitization response observed is similar using an equivalent dose of either
chromium (VI) or chromium (III) (ATSDR, 2000b).
1.2.2
Non-Acute Toxicity
Subchronic toxicity studies in experimental animals have demonstrated hematologic and hepatic
effects from repeated oral exposure to chromium (VI). In a 9 week study in which male and
female Sprague-Dawley rats were fed diets containing potassium dichromate at dose levels of 0,
15, 50, 100, or 400 ppm potassium dichromate [NTP, 1996], there were no treatment related
findings noted in mean body weights, water and feed consumption, organ weights or microscopic
pathology of the liver, kidneys and ovaries. Hematology findings effects consisted of decreases in
mean corpuscular volume (MCV) and mean corpuscular hemoglobin (MCH) at the high dose
(8.4 and 9.8 mg/kg/day in male and female rats respectively). There were no reported hepatic
effects in this study. However, Kumar and Rana (1992) reported increased accumulation of
hepatic lipids after gavage treatment of rats with 13.5 mg/kg chromium (VI) (as potassium
chromate) after 20 days of treatment.
In a 9-week feeding study in mice conducted by the National Toxicology Program (1996) in
which mice were fed diets containing 1.1, 3.5, 7.4, and 32 mg/kg/day chromium (males) or 1.8,
5.6, 12, and 48 mg/kg/day chromium (females), hepatic cytoplasmic vacuolization was observed
to be slightly increased at the high dose in males and females, and the appearance of the vacuoles
was suggestive of lipid accumulation. Additional endpoints examined in this study included body
weights, feed and water consumption, organ weights, microscopic evaluation of the liver, kidney
and ovaries, hematology, histology of the testis and epididymis for Sertoli nuclei, and
preleptotene spermatocyte counts in Stage X or XI tubules and chromatin analysis. Slight
decreases in body weight were observed during this study, but there was no significant effect of
treatment on clinical signs, necropsy findings, or microscopic histology. Hematologic effects
were observed and consisted of a 2-4% decrease in MCV at weeks 3, 6, and 9 in high dose males
and females and at week 6 in the 100 ppm females. The MCV returned to normal in the female
mice after the recovery period (week 17); however the MCV increased 2.8% in the 400 ppm
males.
The MCV changes at weeks 3, 6 and 9 were, in general associated with small decreases in the
RBC, and small decreases in the MCH, although only the MCH values from the 400 ppm males
(week 9), the 400 ppm females (Weeks 3 and 6), the 15 and 100 ppm females (week 3) were
13
decreased.
Occupational exposure to chromium by inhalation has been studied in the chromate
manufacturing and ferrochromium industries; however, exposures all include mixed exposures to
both Cr(III) and Cr(VI). The Cr(VI) species is widely considered to be the causative agent in
reports of excess cancer risk in chromium workers. However, studies are inadequate to rule out a
contribution by Cr(III), and Cr(VI) cannot be unequivocally demonstrated to be the causative
agent for noncarcinogenic effects following inhalation.
A number of epidemiologic studies have considered the association between inhalation of
chromium and noncarcinogenic endpoints, including upper respiratory irritation and atrophy,
lower respiratory effects, and systemic effects. Symptoms reported from inhalation exposure to
mists and dusts containing chromium have included nasal tissue damage, perforated septum,
ulcerated septum, chrome holes, nosebleed, inflamed mucosa, nasal septal perforation, and nasal
septal ulceration (USEPA IRIS, 1998). Exposure to vapors of chromium salts has also been
suspected as a cause of asthma, coughing, wheezing, and other respiratory distress in
ferrochromium workers.
Despite the consistency of the reported effects from inhalation of chromium contained in dusts
and mists, the actual Cr(III) and Cr(VI) exposure levels in many of the studies attributing
respiratory effects to chromium were unknown. In addition, data on other confounding factors
such as smoking were frequently unavailable. These caveats significantly complicate determination
of the potential health effects associated with inhalation exposure to chromium (ATSDR, 2000b).
Although human data examining developmental endpoints are scarce, animal studies have
consistently shown that chromium, particularly chromium(VI), is a developmental toxicant.
Oral ingestion of chromium (VI) compounds in experimental animals results in significant
developmental toxicity. Studies describing the effects observed have been published in the IRIS
Toxicological Reviews for both chromium (VI) and chromium (III) as well as from submitted
studies to the Agency and are summarized here.
Trivedi et al. (1989) exposed mice to 250, 500, and 1,000 ppm potassium dichromate daily
through drinking water during the entire gestational period. The authors reported decreased fetal
weight, increased resorptions, and increased abnormalities (tail kinking, delayed ossification of
the cranium) in exposed mice. The medium- and high-dose groups registered significant
reductions in body weight gain when compared to controls. The most significant finding of the
study was the complete absence of uterine implantation in the high-dose group. The 250 and 500
ppm dose groups also showed significant incidences of resorption as compared to controls. The
authors observed significant increases in preimplantation and postimplantation losses and dosedependent reductions in total weight and crown-rump length in the lower dose groups.
Additional effects included treatment-related increases in abnormalities in the tail, wrist
forelimbs and subdermal hemorrhagic patches in the offspring.
14
Junaid et al. (1996) exposed female Swiss albino mice to 250, 500, or 750 ppm potassium
dichromate in drinking water to determine the potential embryotoxicity of hexavalent chromium
during days 6-14 of gestation. No notable changes in behavior or clinical signs were observed in
the control or treated dams. Chromium levels in blood, placenta, and fetus increased in a dosedependent fashion over the course of the study. The authors reported retarded fetal development
and embryo- and fetotoxic effects including reduced fetal weight, reduced number of fetuses (live
and dead) per dam, and higher incidences of stillbirths and postimplantation loss in the 500 and
750 ppm dosed mothers. Significantly reduced ossification in nasal, frontal, parietal,
interparietal, caudal, and tarsal bones was observed in the high-dose group, while reduced
ossification in only the caudal bones was observed in the 500 ppm dose group. Based on the
body weight of the animals (30 +/- 5 g) and the drinking water ingested by the animals in the 250
ppm dose group (8.0 ml/mouse/day), the dose level in the 250 ppm group can be identified as 67
mg/kg-day. The maternal NOAEL was 63 [22.3] mg/kg/day while the LOAEL was 42.1
mg/kg/day and was based on a decreased gestational body weight. At the lowest dose tested, the
incidence of resorptions was increased and a developmental NOAEL was, therefore, not
determined.
Kanojia et al. (1996) exposed female Swiss albino rats to 250, 500, or 750 ppm potassium
dichromate in drinking water for 20 days 3 months prior to gestation to determine the potential
teratogenicity of hexavalent chromium. No notable changes in behavior or clinical signs were
observed in the control or treated dams. Chromium levels in blood, placenta, and fetus were
significantly increased in the dams of the 500 and 750 ppm dose groups. The authors reported a
reduced number of corpora lutea and implantations, retarded fetal development, and embryo- and
fetotoxic effects including reduced number of fetuses (live and dead) per dam and higher
incidences of stillbirths and postimplantation loss in the 500 and 750 ppm dosed mothers.
Significantly reduced parietal and interparietal ossification was observed in the high-dose group.
Based on the body weight of the animals (175 +/- 25 g) and the drinking water ingested by the
animals in the 250 ppm dose group (26 ml/mouse/day) the dose level in the 250 ppm group can
be identified as 37 mg/kg-day.
Tyl (1991) examined the developmental and maternal effects of daily administration of chromic
acid (55.0% a.i.) at dosages of 0, 0.1, 0.5, 2.0 or 5.0 mg/kg/day by gavage in rabbits. Clinical
signs of toxicity , including diarrhea, and slow, audible or labored breathing were observed in
predominately in the 2.0 and 5.0 mg/kg/day groups. However, these signs did not show a doseresponse and were observed in lesser incidence at 5.0 mg/kg/day vs. 2.0 mg/kg/day. However, the
incidence of mortality (at 2.0 mg/kg/day, one doe died on gestation day (GD) 28; at 5.0
mg/kg/day, 5 does died (one each on GD 10, 14, and two on GD 15) and the magnitude of
decreased body weight gain during the dosing period (average weight loss of 48 grams at 2.0
mg/kg/day, and average weight loss of 140 grams at 5.0 mg/kg/day during gestation days 7-19)
were observed to occur in a dose-related fashion at 2.0 and 5.0 mg/kg/day. Food efficiency was
also observed to be significantly lower during the dosing period in the 5.0 mg/kg/day dose group.
Cesarean section observations were unremarkable in this study at any dose level. No treatment
related effects on either fetal malformations or variations were observed.
15
The Maternal NOAEL = 0.5 [0.12] mg/kg/day and LOAEL = 2.0 [0.48] mg/kg/day (based on the
increased incidence of maternal mortality and decreased body weight gain ). The Developmental
NOAEL = 2.0 [0.48] mg/kg/day and LOAEL > 2.0 [>0.48] mg/kg/day based on the lack of
developmental effects at any dose level tested.
By contrast to effects of chromium (VI), effects on development and reproduction from exposure
to Cr (III) show either negative results or effects only at high doses. For example, male and
female rats treated with 1,806 mg Cr(III) kg/day as Cr(III) oxide 5 days/week for 60 days before
gestation and throughout the gestation period had normal fertility, gestational length, and litter
size (Ivankovic and Preussman, 1975). Elbetieha and Al-Hamood (1997) examined fertility
following chromium chloride exposures in mice. Sexually mature male and female mice were
exposed to 1,000, 2,000, or 5,000 mg/L chromium chloride in drinking water for 12 weeks.
Exposure of male mice to 5,000 ppm trivalent chromium compounds for 12 weeks had adverse
impacts on male fertility. Testes weights were increased in the males exposed in the 2,000 and
5,000 mg/L dose groups, while seminal vesicle and preputial gland weights were reduced in the
5,000 mg/L exposed males. The number of implantation sites and viable fetuses were significantly
reduced in females exposed to 2,000 and 5,000 mg/L chromium chloride. Water consumption was
not reported precluding calculation of the doses received. However it is evident that adverse
effects were observed only at a high dose of Cr (III).
The National Toxicology Program recently conducted a three-part study to investigate
oral ingestion of hexavalent chromium in experimental animals (NTP, 1996a,b, 1997).
The study included a determination of the potential reproductive toxicity of potassium
dichromate in Sprague-Dawley rats, a repeat of the study of Zahid et al. (1990) using BALB/C
mice, and a Reproductive Assessment by Continuous Breeding study in BALB/C mice.
The study in the Sprague-Dawley rat (NTP, 1996a) was conducted in order to generate
data in a species commonly used for regulatory studies. Groups of 24 males and 48 females were
exposed to 0, 15, 50, 100, or 400 ppm potassium dichromate daily in the diet for 9 weeks
followed by a recovery period of 8 weeks. Six male and 12 female rats were sacrificed after 3, 6,
or 9 full weeks of treatment or after the full recovery period. Animals were examined for body
weights; feed and water consumption; organ weights; microscopic evaluation of the liver, kidney,
and ovaries; hematology; histology of the testis and epididymus for Sertoli nuclei and
preleptotene spermatocyte counts in Stage X or XI tubules; and chromatin analysis. No
treatment-related hematology findings were reported except for slight decreases in MCV and
MCH values in the male and female treatment groups receiving 400 ppm potassium dichromate
(24 mg/kg-day). While the trends in MCV and MCH were not large and were within the
reference ranges, they are consistent with the findings of the companion studies in BALB/C mice
and were characterized by the authors as suggestive of a potential bone marrow/erythroid
response. The authors considered the 100 ppm (6 mg/kg-day) dose group to be representative of
the NOAEL for the study.
The reproductive study in BALB/C mice (NTP, 1996b) was conducted to reproduce the
conditions utilized by Zahid et al. (1990) in their examination of comparative effects of trivalent
16
and hexavalent chromium on spermatogenesis of the mouse. Groups of 24 male and 48 female
BALB/C mice were exposed to 0, 15, 50, 100, or 400 ppm potassium dichromate in the diet for 9
weeks followed by a recovery period of 8 weeks. Six male and 12 female mice were sacrificed
after 3, 6, or 9 full weeks of treatment or after the full recovery period. Animals were examined
for body weights; feed and water consumption; organ weights; microscopic evaluation of the
liver, kidney, and ovaries; hematology; histology of the testis and epididymus for Sertoli nuclei
and preleptotene spermatocyte counts in Stage X or XI tubules; and chromatin analysis.
Treatment-related effects included a slight reduction in the mean body weights in the 400 ppm
males and the 100 ppm females, a slight increase in food consumption at all dose levels, a slight
decrease in MCV and MCH at 400 ppm, and cytoplasmic vacuolization of the hepatocyte at 50,
100 and 400 ppm. None of the effects on spermatogenesis reported by Zahid et al. (1990) were
observed in this study. On the basis of the cytoplasmic vacuolization of the hepatocyte in the 50,
100, and 400 ppm dose groups, the authors selected 15 ppm (4 mg/kg-day) as the NOAEL.
Increased resorptions and increased post-implantation loss as well as gross fetal abnormalities
were observed in offspring of pregnant mice exposed to potassium dichromate at 57 mg/kg/day in
drinking water during gestation (ATSDR, 2000b). At a higher dose of 234 mg/kg/day, no
implantations were observed in maternal mice. In a second study in mice, potassium dichromate
was administered in the diet for 7 weeks at dose levels of 15.1 and 28 mg/kg/day. Reduced sperm
counts and degeneration of the outer layer of the seminiferous tubules was observed at the 15.1
mg/kg/day dose, and morphologically altered sperm was observed at the 28 mg/kg/day dose.
In male rats administered 20 mg/kg/day chromium trioxide for 90 days by gavage, reduced
testicular weight, decreased testicular testosterone, and reduced Leydig cell number was observed
(Chowdhury and Mitra, 1995).
Despite the wealth of animal studies on the developmental and reproductive toxicity of chromium
VI, there are too few human data with which to make any reliable conclusion regarding the
susceptibility of the developing fetus, infants, or children to the toxic effects of chromium VI. The
evidence available suggests similar toxic effects in adults and children from ingestion of chromium
VI (ATSDR, 2000b).
Hexavalent chromium (Cr VI) is known to be carcinogenic in humans by the inhalation route of
exposure. Results of occupational epidemiologic studies of chromium-exposed workers are
consistent across investigators and study populations. Dose-response relationships have been
established for chromium exposure and lung cancer. Chromium-exposed workers are exposed to
both Cr(III) and Cr(VI) compounds. Because only Cr(VI) has been found to be carcinogenic in
animal studies, however, it was concluded that only Cr(VI) should be classified as a human
carcinogen.
Animal data are consistent with the human carcinogenicity data on hexavalent chromiumby the
inhalation route. Hexavalent chromium compounds are also carcinogenic in animal bioassays by
other routes of exposure, such as: intramuscular injection site tumors in rats and mice,
17
intrapleural implant site tumors for various Cr(VI) compounds in rats, intrabronchial implantation
site tumors for various Cr(VI) compounds in rats, and subcutaneous injection site sarcomas in rats
(IRIS, 2001). However, these routes of administration are not relevant to exposures of chromium
in CCA-treated wood.
Data addressing human carcinogenicity from exposures to Cr(III) alone are not available, and data
are inadequate for an evaluation of human carcinogenic potential. Two oral studies located in the
available literature (Schroeder et al., 1965; Ivankovic and Preussman, 1975) reported negative
results for rats and mice. Several animal studies have been performed to assess the carcinogenic
potential of Cr(III) by inhalation. These studies have not found an increased incidence of lung
tumors following exposure either by natural routes, intrapleural injection, or intrabronchial
implantation (Baetjer et al., 1959; Hueper and Payne, 1962; Levy and Venitt, 1975; Levy and
Martin, 1983).
The data from oral and inhalation exposures of animals to trivalent chromium do not support
determination of the carcinogenicity of trivalent chromium. IARC (1990) concluded that animal
data are inadequate for the evaluation of the carcinogenicity of Cr(III) compounds. Furthermore,
although there is sufficient evidence of respiratory carcinogenicity associated with exposure to
chromium, the relative contributions of Cr(III), Cr(VI), metallic chromium, or soluble versus
insoluble chromium to carcinogenicity cannot be elucidated.
In vitro data are suggestive of a potential mode of action for hexavalent chromium carcinogenesis.
Hexavalent chromium carcinogenesis may result from the formation of mutagenic oxidatitive
DNA lesions following intracellular reduction to the trivalent form. Cr(VI) readily passes through
cell membranes and is rapidly reduced intracellularly to generate reactive Cr(V) and Cr(IV)
intermediates a reactive oxygen species. A number of potentially mutagenic DNA lesions are
formed during the reduction of Cr(VI). Hexavalent chromium is mutagenic in bacterial assays,
yeasts, and V79 cells, and Cr(VI) compounds decrease the fidelity of DNA synthesis in vitro and
produce unscheduled DNA synthesis as a consequence of DNA damage. Chromate has been
shown to transform both primary cells and cell lines (ATSDR, 2000b).
Intracellular reduction of Cr(VI) generates reactive chromium V and chromium IV intermediates
as well as hydroxyl free radicals (OH) and singlet oxygen. A variety of DNA lesions are generated
during the reduction of Cr(VI) to Cr(III), including DNA strand breaks, alkali-labile sites, DNAprotein and DNA-DNA crosslinks, and oxidative DNA damage, such as 8-oxo-deoxyguanosine.
The relative importance of the different chromium complexes and oxidative DNA damage in the
toxicity of Cr(VI) is unknown.
Hexavalent chromium has been shown to be genotoxic only in the presence of appropriate
reducing agents in vitro or in viable cell systems in vitro or in vivo. Hexavalent chromium has
been shown to be mutagenic in bacterial systems in the absence of a mammalian activating
system, and not mutagenic when a mammalian activating system is present. Hexavalent chromium
is also mutagenic in eukaryotic test systems and clastogenic in cultured mammalian cells.
18
Hexavalent chromium in the presence of glutathione has been demonstrated to produce genotoxic
DNA adducts that inhibit DNA replication and are mutagenic (IRIS, 2000). Chromium (III) has
also produced positive mutagenic responses in vitro (IRIS, 2000).
1.2.3 Metabolism
Absorption of chromium by the oral route ranges from essentially zero for the insoluble chromium
III compound chromic oxide to 10% for potassium chromate. Absorption through exposure in the
diet, in water, or from contaminated soil is consistently low, with values reported in the range of
1-5% (ATSDR, 2000b; USEPA, 1998). Hexavalent chromium can be reduced to the trivalent
form in the epithelial lining fluid of the lungs by ascorbate and glutathione as well as by gastric
juice in the stomach, which contributes to the low oral absorption. Absorption by the dermal route
is also low (1.3% after 24 hours as reported by Bagdon et al., 1991)
Once absorbed, chromium compounds are distributed to all organs of the body without any
preferential distribution to any one organ. However, exposures to higher levels of chromium, such
as can occur in the chrome plating industry and chrome refining plants, may result in accumulation
of chromium in tissues. Witmer et al. (1989, 1991) studied chromium distribution in tissues of rats
administered chromium via gavage. In one experiment, the highest dose of sodium chromate [5.8
mg Cr(VI)/kg/day for 7 days] resulted in concentrations of chromium in the tissues in the
following order: liver (22 ?g chromium/whole organ) > kidney (7.5 ?g) > lung (4.5 ?g) > blood
(2 ?g) > spleen (1 ?g). These tissues combined retained about 1.7% of the administered dose;
however, some tissues were not analyzed. At the two lower doses administered (1.2 or 2.3
mg/kg/day), very little chromium was detected (<0.5 µg/organ) in the organs analyzed.
Maruyama (1982) studied the chromium content in major organs of mice exposed to potassium
dichromate [Cr(VI)] or chromium trichloride ([Cr(III)] for 1 year in drinking water. Groups of
mice received 4.4, 5.0 or 14.2 mg Cr(VI)/kg/day or 4.8, 6.1 or 12.3 mg Cr(III)/kg/day.
Examination of organs and blood in mice that received Cr(VI) revealed that the liver and spleen
had the highest levels of chromium, although some chromium accumulation was observed in all
tissues. In mice that received Cr(III), the liver was the only organ with detectable amounts of
chromium, and at levels that were about 40-90 times less than in mice that received the Cr(VI)
compound. MacKenzie et al. (1958) reported that in rats following the administration of similar
concentrations of Cr(VI) as potassium chromate or Cr(III) as chromium trichloride in drinking
water for 1 year, tissue levels were approximately 9 times greater in rats that received the Cr(VI)
compound, compared to rats that received the Cr(III) compound.
If hexavalent chromium is absorbed, it can readily enter red blood cells through facilitated
diffusion, where it will be reduced to the trivalent form by glutathione. During reduction to the
trivalent form, chromium may interact with cellular macromolecules, including DNA (Wiegand et
al., 1985), or may be slowly released from the cell (Bishop and Surgenor, 1964). Chromium III
can be cleared rapidly from the blood but more slowly from tissues, which may be related to the
formation of trivalent chromium complexes with proteins or amino acids (Bryson and Goodall,
19
1983).
The liver is a primary site of chromium metabolism and has been studied in animals. Incubation of
Cr(VI) with rat liver microsomes in the presence of the enzyme cofactor nicotinamide adenine
dinucleotide phosphate (NADPH) resulted in the reduction of Cr(VI) to Cr(III) (ATSDR, 2000b).
Exclusion of the co-factors necessary for the production of NADPH resulted in a large decrease
in the reduction of Cr(VI) to Cr (III).
Chromium metabolism can result in the formation of species that interact with deoxyribonucleic
acid (DNA). The reduction of Cr(VI) to a Cr(V) intermediate involves a single electron transfer
from the microsomal electron-transport cytochrome P-450 system (Jennette 1982). These
reactive Cr(V) complexes/ intermediates are relatively unstable and persist for approxim-ately 1
hour in vitro. During this time the Cr(V) complexes/ intermediates can interact with
deoxyribonucleic acid (DNA), which may eventually lead to cancer. When Cr(VI) interacts with
glutathione, Cr(V) complexes and glutathione thonyl radicals were produced, and when Cr(VI)
interacts with DNA and glutathione, DNA adducts were formed (Aiyar et al. 1989). The
formation of Cr(V) was found to correlate with DNA adduct formation. Following reactions of
Cr(VI) with hydrogen peroxide, hydroxyl radicals were produced; the addition of DNA resulted in
the formation of an 8-hydroxy guanine adduct and DNA strand breakage.
The elimination of chromium after oral exposure has been studied in both humans and animals. In
one study, human volunteers received an acute oral dose of radiolabeled Cr(III) or Cr(VI)
(Donaldson and Barreras 1966). Fecal samples were collected for 24 hours, and urine samples
were collected for 6 days and analyzed for chromium. Approximately 99.6% of the Cr(III)
compound was recovered in the 6-day fecal sample, while 89.4% of the Cr(VI) compound was
recovered. The results of the analysis of the 24-hour urine samples indicated that 0.5% and 2.1%
of the administered dose of the Cr(III) and the Cr(VI) compounds, respectively, were recovered
in the urine. Other potential routes of excretion include hair, fingernails and breast milk (ATSDR
2000b).
In several studies in which rats and hamsters were fed Cr(VI) compounds, fecal excretion of
chromium varied slightly from 97% to 99% of the administered dose, and urinary excretion of
chromium, administered as Cr(III) or Cr(VI) compounds, varied from 0.6% to 1.4% of the dose
(Donaldson and Barreras 1966, Henderson et al. 1979, Sayato et al. 1980). Following the gavage
administration of 13.92 mg chromium/kg/day as calcium chromate for 8 days, the total urinary
and fecal excretion of chromium on days 1 and 2 of dosing were <0.5% and 1.8%, respectively
(Witmer et al. 1991). The total urinary and fecal excretion of chromium on days 7 and 8 of
dosing were 0.21% and 12.35%, respectively. Donaldson et al. (1984), reported that excretion of
Cr(III) and creatinine clearance were almost equal suggesting that tubular absorption or
reabsorption of chromium in the kidneys was minimal.
2.0
DOSE-RESPONSE ASSESSMENT
20
The process of dose-response assessment as part of a total risk assessment involves describing the
quantitative relationship between the exposure to a chemical and the extent of toxic injury or
disease. Following the process of hazard identification, in which the available toxicology data is
reviewed and selection of NOAELs and LOAELs is made for each study, the reviewed data for a
pesticide chemical is presented to a committee of scientists within the Office of Pesticide
Programs who reach concurrence on toxicology endpoints that best represent the toxic effects
expected from various routes of exposure and durations of exposure. For most pesticide
chemicals, the process results in selection of acute and chronic Reference Dose values (which can
be used as benchmark values for acute and chronic dietary risk calculations), as well as endpoint
values for non-dietary risk assessments involving occupational and/or residential exposures by the
oral, dermal, and inhalation routes. Endpoints are selected for non-dietary exposures to represent
short-term (1-30 days), intermediate-term (30-180 days), and long-term exposure scenarios, as
needed. In addition, incidental oral exposure endpoints are selected for short-term and
intermediate term exposure durations to represent ingestion of pesticide chemical residues that
may occur from hand-to-mouth behaviors. In general, toxicity endpoint selection should, to the
extent possible, match the temporal and spatial characteristics of the exposure scenarios selected
for use in the risk assessment. These endpoints are then used in conjunction with exposure values
to calculate risks associated with various types of exposure, depending upon the uses of the
pesticide chemical.
Toxicology endpoints for both inorganic arsenic and chromium have been selected for the
residential exposure assessment and are presented below:
21
2.1
Inorganic Arsenic-Endpoint Selection
On August 21, 2001, the OPP’s Hazard Identification Assessment Review Committee (HIARC)
evaluated the toxicology data base of Inorganic Arsenic and established the toxicological
endpoints for occupational exposure risk assessments. On October, 23-25 2001, the FIFRA
Scientific Advisory Panel (SAP) met and discussed some issues about the end points proposed by
the HIARC. The inorganic arsenic toxicological end-points selected for CCA occupational risk
assessment are summarized in Table 4.
2.1.1 Acute Reference Dose (aRfD)
In the Office of Pesticide Program (OPP) in EPA, the acute reference dose (aRfD) was used in
the risk assessment associated with oral exposure to food related chemicals. Inorganic arsenic is
not registered for any food uses and there are no existing tolerances. For inorganic arsenic as
contained within CCA-treated wood, therefore, an acute RfD is not relevant to the exposures
from registered use.
2.1.2 Chronic Reference Dose (cRfD)
The U.S. EPA has published a chronic RfD value for inorganic arsenic (USEPA IRIS, 1998).
However, as with the acute RfD, in OPP, the chronic RfD in OPP was considered for evaluating
risks associated with food and/or drinking water related chemical uses. Because there are no
exposure scenarios relevant to the currently registered uses of inorganic arsenic, and specifically
the registered uses in CCA-treated lumber. No chronic RfD value is need for the current inorganic
arsenic use in CCA-treated wood use. However, if the Agency determines in the future that an
aggregate assessment is needed for calculation of risk from exposure to arsenic in treated lumber
and exposure in drinking water and/or food, the chronic RfD value can be utilized.
2.1.3 Short (1-30 days ) and Intermediate (30-180 days) Incidental Oral Exposure
Based on the registered use of CCA-treated lumber for fencing and decking materials in
residential settings, incidental oral exposure is expected, based on potential ingestion of soil
contaminated with arsenic as a result of leaching from wood, and from ingestion of arsenic
residues from the palm as a result of direct dermal contact with treated wood. The studies
selected for short- and intermediate-term incidental oral exposure are the human case reports of
Franzblau and Lilis (Arch. of Envir. Health 44(6): 385-390, 1989) and Mizuta et al. (Bull.
Yamaguchi Med. Sch. 4(2-3): 131-149, 1956). The LOAEL of 0.05 mg/kg/day was selected,
based on facial edema, gastrointestinal symptoms, neuropathy, and skin lesions observed at this
dose level
Franzblau et al., (1989) reported 2 cases of subchronic (2 months) arsenic intoxication resulting
from ingestion of contaminated well water (9-10.9 mg/L) sporadically (once or twice a week) for
about 2 months. Acute gastrointestinal symptoms, central and peripheral neuropathy, bone
22
marrow suppression, hepatic toxicity and mild mucous membrane and cutaneous changes were
presented. The calculated dose was 0.03 - 0.08 mg/kg/day based on a body weight of 65 Kg and
ingestion of from 238 to 475 ml water/day.
Mizuta et al. (1956) reported a poisoning incident involving the presence of arsenic [probably
calcium arsenate] contained in soy-sauce. The duration of exposure was 2-3 weeks. The arsenic
content was estimated at 0.1 mg/ml. Out of 417 patients, the authors reported on 220 (age not
specified for all patients. The age of the 46 paints with age information are ranging from 15 - 69).
An early feature of the poisoning was appearance of facial edema that was most marked on the
eyelids. Other symptoms presented included multifaceted gastrointestinal symptoms, liver
enlargement, upper respiratory symptoms, peripheral neuropathy and skin disorders. In the
majority of the patients, the symptoms appeared within two days of ingestion and then declined
even with continued exposure. There was evidence of minor gastrointestinal bleeding (occult
blood in gastric and duodenal juice). There were abnormalities in electrocardiograms (altered Q-T
intervals and P and T waves). These changes were not evident on reexamination after recovery
from the clinical symptoms. An abnormal patellar reflex was evident in >50% of the cases. This
effect did not return to normal during the course of the investigation.
Based on the consumption of the arsenic in the contaminated soy-sauce, the pattern of soy-sauce
consumption and on measured urinary arsenic levels, the authors estimated consumption of
arsenic at 3 mg/day. Although the body weight was not reported, the EPA assumes an average
body weight of 55 kg in the Asian population. The estimated exposure was, therefore, 0.05
mg/kg/day and was considered the LOAEL. The LOAEL= 0.05 mg/kg/day (edema of the
face; gastrointestinal, upper respiratory, skin, peripheral and neuropathy symptoms).
These two case reports are appropriate for both short- and intermediate-term incidental oral
endpoints for the following reasons:
1) Symptoms reported in the Mizuta study (gastrointestinal disorders, neuropathy, liver
toxicity) occurred after 2-3 weeks of exposure, making this endpoint appropriate for the
short-term (1-30 days) exposure period. This study also examined toxicity by the relevant
route of exposure (oral).
2) Similar symptoms were observed in the Franzblau study, and are appropriate for the
intermediate-term endpoint as they were observed to occur after longer-term (2 months)
exposure.
A Margin of Exposure (MOE) of 30 applied to the LOAEL was suggested the majority of the
SAP panel members in the 2001 meeting.
USEPA Region 8 has also published a report on selection of acute and chronic Reference Doses
for Inorganic Arsenic, intended to apply to exposures of 1-14 days and 15 days-7 years (USEPA
Region 8, 2001). The use of the term “reference dose” in the Region 8 report “apply to readily
23
soluble forms of arsenic and are intended to include total oral exposure to inorganic arsenic, that
is drinking water, food, and soil. “ The report concludes that a NOAEL value of 0.015
mg/kg/day from a study by Mazumder et al (Int. J. Epidem. 27: 871-877) can be used for acute
and subchronic reference dose values, with an uncertainty factor of 1. Alternately, the LOAEL of
0.05 mg/kg/day and an uncertainty factor of 3 (for extrapolation from the LOAEL to the
NOAEL) could be selected from this same study. A full factor of 10 was not employed by
Region 8 based on the reasoning that a No Adverse Effect Level “is likely at an exposure only
slightly below the effect level” (USEPA Region 8, 2001). However, this report did not discuss
severity or irreversibility of effects observed in the Mizuta et al. report as a factor in selecting the
uncertainty factor, which was taken into consideration by the OPP HIARC. Further, the effect
observed in the Mazumder et al. study of hyperkeratosis is a result of chronic exposure and not
short- or intermediate-term exposure and was thus felt to be inappropriate for determination of
short- and intermediate-term incidental oral risk. The Region 8 report was part of the background
documents presented to the 2001 SAP.
For the risk assessment, based on the recommendations of the SAP, the Agency decided to use a
Margin of Exposure (MOE) of 30. This value of 30 was recommended on the basis that the
severity of symptoms near or moderately above the LOAEL (0.05mg/kg/day) warranted a full
uncertainty factor of 10 and an uncertainty factor of 3 for protection of children.
2.1.4 Dermal Absorption
Dermal absorption of inorganic arsenic is represented by the study of Wester et al. (Fund. Appl.
Toxicol. 20: 336-340, 1993). In this study, the percutaneous absorption of arsenic acid (H 3AsO4)
from water and soil both in vivo using rhesus monkeys and in vitro with human skin was
examined. In vivo, absorption of arsenic acid from water (loading 5 µl/cm2 skin area) was 6.4 ±
3.9% at the low dose (0.024 ng/cm 2) and 2.0 ± 1.2% at the high dose (2.1 µg/cm 2). Absorption
from soil (loading 0.04 g soil/cm2 skin area) in vivo was 4.5 ± 3.2% at the low dose (0. 04
ng/cm2) and 3.2 ± 1.9% at the high dose (0.6 µg/cm 2). Thus, in vivo in the rhesus monkey,
percutaneous absorption of arsenic acid is low from either soil or water vehicles and does not
differ appreciably at doses more than 10,000-fold apart. Wester et al. (1993) also reported that for
human skin, at the low dose, 1.9% was absorbed from water and 0.8% from soil over a 24-h
period.
The value of 6.4% dermal absorption was chosen based on the use of non-human primates for
derivation of this value and the fact that this was a well-conducted study. It is observed in this
study that a higher dose on the skin resulted in lower dermal absorption as noted above, but the
data in this and other studies suggests sufficient variability in the absorption such that use of the
6.4% dermal absorption value is sufficiently but not overly conservative. For children playing
around playground equipment, however, it is assumed the dermal exposure would be arsenic in
wood surface residue and/or arsenic in soil, a dermal absorption value of 3% will be used (SAP,
2001).
24
2.1.5
Short (1-30 days ) and Intermediate (30-180 days) Dermal Exposure
Since there is no appropriate dermal studies, same as studies selected for short- and intermediateterm incidental oral exposure, the case reports of Franzblau and Lilis (Arch. of Envir. Health
44(6): 385-390, 1989) and Mizuta et al. (Bull. Yamaguchi Med. Sch. 4(2-3): 131-149, 1956)
were selceted for short (1-30 days ) and intermediate (30-180 days) term dermal exposure
scenarios. The LOAEL of 0.05 mg/kg/day was selected, based on facial edema, gastrointestinal
symptoms, neuropathy, and skin lesions observed at this dose level. An Margin of Exposure
(MOE) of 30 should be applied to the LOAEL. This value consists of a 10x factor for
intraspecies variation and a 3x factor for extrapolating from a LOAEL to a NOAEL.
2.1.6 Long-Term Dermal Exposure
While no long-term dermal exposures are expected from residential exposure to arsenic in CCAtreated lumber, long-term dermal exposure is expected in the occupational setting. Thus, for this
exposure scenario, the dose and endpoint selected are the NOAEL of 0.0008 mg/kg/day from the
Tseng et al. (1968) study, which examined chronic non -cancer and cancer effects from arsenic
exposure through well water in a large cohort in Taiwan.
In Taiwan, Tseng, (1977), Tseng, (1968) [U.S. EPA, 1998] noted that hyperpigmentation,
keratosis and possible vascular complications were seen at the LOAEL of 0.17 mg/L, converted
to 0.014 mg/kg/day.
The NOAEL was based on the arithmetic mean of 0.009 mg/L in a range of arsenic concentration
of 0.001 to 0.017 mg/L. The NOAEL also included estimation of arsenic from food. Since oral
arsenic exposure data were missing, arsenic concentrations in sweet potatoes and rice were
estimated as 0.002 mg/day. Other assumptions included consumption of 4.5 L water/day and 55
kg body weight (Abernathy, (1989). Thus, the converted NOAEL = [(0.009 mg/L x 4.5 L/day) +
0.002 mg/day]/55 kg = 0.0008 mg/kg/day. The LOAEL dose was estimated using the same
assumptions as the NOAEL starting with an arithmetic mean water concentration from Tseng,
(1977) of 0.17 mg/L. LOAEL = [(0.17 mg/L x 4.5 L/day)+ 0.002 mg/day]/55 kg = 0.014
mg/kg/day. Therefore the NOAEL = 0.0008 mg/kg and the LOAEL= 0.014 mg/kg/day (based
on hyperpigmentation, keratosis and possible vascular complications )
An MOE of 3 is applied to this risk assessment. A factor of 3 and not 10 is used based on the
large sample size of the Tseng study (> 40,000) and is in agreement with the published value and
rationale in the 1998 IRIS document on inorganic arsenic.
2.1.7 Short-, Intermediate-, and Long-term Inhalation Exposure
Short-, intermediate-, and long-term endpoints were not identified in the HIARC report for
inhalation exposures to arsenic. Since no inhalation studies are available, committee selected the
same studies as for the dermal risk assessments. Since the dose identified for inhalation risk
assessments are from oral studies, route-to-route extrapolation should be as follows:
25
Step I: The inhalation exposure component (i.e., g a.i./day) using a 100%
(default) absorption rate and application rate should be converted to an
equivalent oral dose (mg/kg/day);
Step II: The dermal exposure component (i.e., mg/kg/day) using 6.4 % absorption
factor and application rate should be converted to an equivalent oral dose.
The dose should be combined with the converted oral dose in Step I.
Step III:To calculate the MOE's, the combined dose from Step I and II should then
be compared to the oral LOAEL of 0.05 mg/kg/day for short and
intermediate term exposure and the oral NOAEL of 0.0008 mg/kg/day for
long-term exposure.
As discussed in endpoints selected for dermal exposure scenarios (Sections 2.1.5 and 2.1.6),
acceptable Margin of Exposure (MOE) of 30 should be applied to the short- and intermediate
inhalation scenarios. For long-term inhalation exposure scenarios, an acceptable margin of
exposure of 3 should be applied.
2.1.8 Carcinogenicity
There is sufficient evidence from human data indicating arsenic exposure can cause cancer. An
increased lung cancer mortality was observed in multiple human populations exposed primarily
through inhalation. Also, increased mortality from multiple internal organ cancers (liver, kidney,
lung, and bladder) and increased incidences of skin cancer were observed in populations
consuming drinking water high in inorganic arsenic. In order to evaluate the cancer risk
associated with arsenic exposure in drinking water, in 1997, at EPA's request, the National
Academy of Sciences' (NAS) Subcommittee on Arsenic of the Committee on Toxicology of the
National Research Council (NRC) met. Their charge was to review EPA's assessments of arsenic.
The NAS/NRC Subcommittee finished their work in March 1999. In general, the NRC report
confirms and extends concerns about human carcinogenicity of drinking water containing arsenic
and offers perspective on dose-response issues and needed research. The NRC recommended
that EPA analyze risks of internal cancers both separately and combined.
EPA applied many of the recommendations from the 1999 NRC report in the risk characterization
used to support the January 2001 revised arsenic drinking water regulation. In the risk
assessment, EPA used risk estimates taken from Morales et al. (2000). Morales et al. fit a variety
of dose-response models to lung and bladder cancer data from an arseniasis-endemic region of
southwestern Taiwan. Risk was assumed to increase linearly with dose, from zero to the effective
dose (central estimate) at which 1% of population is affected by the chemical (ED01). The slope
of the line extrapolated from ED01 to the origin was calculated and used as the cancer slope
factor for cancer risk assessment (see Plot 1 as an example). In the risk assessment associated
with inorganic arsenic in drinking water in 2000 (EPA,
2001), EPA presented two sets of risk estimates, higher and lower:
26
•
For the higher set of risks: For the higher set of risks: EPA used the theoretical
risk estimates taken directly from Morales et al. (2000). Assumed drinking water
consumption in Taiwanese population is 3.5 L/day for male and 2.0 L/day for
female.
•
For the lower set of risks: For the lower set of risks: EPA adjusted the theoretical
risks to take into account possible higher arsenic consumption in Taiwan. For
these estimates, EPA assumed that people in Taiwan consumed an additional 1 L/d
of water in cooking, due to dehydration of rice and sweet potatoes, and a further
50 µg/d of arsenic directly from their food.
Following the risk assessment associated with inorganic in drinking water are presented in 2000,
EPA asked the National Research Council (NRC) to meet again to: (1) review EPA's
characterization of potential human health risks from ingestion of inorganic arsenic in drinking
water;(2) review the available data on the carcinogenic and non-carcinogenic effects of inorganic
arsenic; (3) review the data on the metabolism, kinetics and mechanism(s)/mode(s) of action of
inorganic arsenic; and (4) identify research needs to fill data gaps.
PLOT 1: Example of how the cancer risk estimations are derived
27
In 2001, NRC published an update to the 1999 NRC report and concluded that (1)
arsenic- -induced bladder and lung cancers still should be the focus of an arsenic-related cancer
risk assessment; (2) the southwestern Taiwan data are still the most appropriate for
arsenic-related cancer risk assessments; and (3) present modes of action data are not sufficient to
depart from the default assumption of linearity. The 2001 NRC update also made specific
recommendations with respect to the overall cancer risk estimate.
The Agency is currently considering the best way to address all the NRC’s recommendations.
Based on the Agency's considerations of these recommendations, the current proposed cancer
potency number may change in the final version of this risk assessment. For this risk assessment,
an oral cancer slope factor of 3.67 (mg/kg/day) -1 was used. This is the mean slope factor derived
from the higher risk approach for both lung and bladder cancers. This slope factor was used by
the EPA’s Office of Water when it established the MCL for arsenic in drinking water (U.S. EPA,
2001) and also by the Consumer Product Safety Commission when it performed its deterministic
assessment for children’s risks from CCA-treated playsets in March 2003 (CPSC, 2003).
The slope factor published by EPA’s Integrated Risk Information System (IRIS), 1.5
(mg/kg/day)-1 , is also being revisited in FY2003 due to the recommendation by the NRC in
2001. If the Agency had used the current IRIS cancer slope factor (1.5 (mg/kg/day)-1 ) instead
of the slope factor used in the Office of Water’s arsenic MCL document (3.67
(mg/kg/day)-1)(U.S. EPA, 2001), the cancer risk would be approximately 41% of the current
cancer risk estimates in this document . For example, a reported cancer risk of 5.0E-4 using the
cancer slope factor of 3.67(mg/kg/day) -1 would be equivalent to 2.0E-4 using the IRIS cancer
slope factor of 1.5 (mg/kg/day) -1.
For inhalation exposure route, in this risk assessment, the cancer endpoint is 4.3 x 10-3 ( g/m3) -1
which is equivalent to a cancer slope factor of 15.1 (mg/kg/day)-1 (EPA, 1989). All the EPA
proposed Q1* are summarized in Table 3.
28
Table 3.
Cancer Slope Factor used for Assessing Cancer Risks Associated with
Occupational Exposures/Risks to Inorganic Arsenic
Oral Slope Factors (Q1*) Based on the EPA’s Integrated Risk Information System (IRIS) (Last
Revised -- 04/10/1998)
Based on Internal organ cancer (liver, kidney, lung and bladder) and skin cancer
Slope Factor (Q1*) (a)
1.5E+0 per (mg/kg)/day
Oral Slope Factors (Q1*) Based on the EPA’s Risk Assessment Associated with Drinking Water
(EPA, 2001)
Lower Set (a)
Higher Set (a)
(per (mg/kg)/day)
(per (mg/kg)/day)
Based on Bladder Cancer
Male:
Female:
1.49
2.15
0.18
0.25
Based on Lung Cancer:
Male:
Female:
1.60
2.10
0.23
0.27
Based on Bladder+Lung Cancer:
Male:
Female:
Combine Male and Female
3.09
4.25
3.67 (b)
0.30
0.37
0.33
Inhalation Slope Factors (Q1*) Based on the EPA’s Integrated Risk Information System (IRIS) (Last
Revised -- 04/10/1998)
Based on Skin Cancer
Slope Factor (Q1*)
(c)
15.1 per (mg/kg)/day
Note:
(a). EPA's assumptions for its high and low risk estimates is as follows:
Low
risk
Drinking water consumption, U.S.
L/d
1
Cooking water consumption, Taiwan
L/d
1
Additional As consumed in food, Taiwan µg/d
50
High
risk
1.2
0
0
(b). Q1* of 3.67 per (mg/kg)/day is the number be used in this risk assessment.
Attachment 1 presents how the slope factor was derived.
(c). Q1* derived from a inhalation unit risk of 4.3 x 10-3 ( g/m3) -1. Unit risk= Q1* x 1/70 kg x 20
m 3/day x 1 g/1,000 mg (EPA, 1989).
29
Table 4.
Toxicological Endpoints for Assessing Occupational Exposures/Risks to Arsenic (V)
EXPOSURE
SCENARIO
DOSE
(mg/kg/day)
ENDPOINT
Acute Dietary
This risk assessment is not required.
Chronic Dietary
This risk assessment is not required.
Incidental Short- and
Intermediate- Term
Oral
LOAEL= 0.05
Dermal Short- and
Intermediate-Term (a) (b)
LOAEL= 0.05
MOE = 30
MOE = 30
(a)
Dermal Long-Term
(b)
NOAEL= 0.0008
STUDY
Based on edema of the face,
gastrointestinal, upper respiratory, skin,
peripheral and neuropathy symptoms
Franzblau et al.(1989) and
Mizuta et al. (1956)
Based on edema of the face,
gastrointestinal, upper respiratory, skin,
peripheral and neuropathy symptoms
Franzblau et al.(1989) and
Mizuta et al. (1956)
Based on hyperpigmentation, keratosis and
possible vascular complications.
Tseng et al. (1968) and
Tseng (1977)
Based on edema of the face,
gastrointestinal, upper respiratory, skin,
peripheral and neuropathy symptoms
Franzblau et al.(1989) and
Mizuta et al. (1956)
Based on hyperpigmentation, keratosis and
possible vascular complications.
Tseng et al. (1968) and
Tseng (1977)
MOE = 3
Inhalation Short- and
Intermediate-Term (c)
LOAEL= 0.05
MOE = 30
Inhalation, Long-Term
NOAEL= 0.0008
MOE = 3
Carcinogenicity Inhalation
(Inhalation Unit Risk)
Q1*= 15.1 (d)
(mg/kg/day) -1
Lung cancer
Chronic epidemiological
inhalation study on humans
Carcinogenicity - Oral
Ingestion
(Oral and Dermal
Risks)
Q1* = 3.67
(mg/kg/day)-1
Internal organ cancer (liver, kidney, lung and
bladder) and skin cancer
Chronic epidemiological oral
study on humans
Note:
(a).
(b).
(c).
(d).
MOE = Margin of Exposure; NOAEL = No observed adverse effect level; and LOAEL = Lowest observed
adverse effect level.
The dermal absorption factor = 6.4%. (Note: The FIFRA Scientific Advisory Panel recommended use of a lower
value of 2-3%. The occupational assessment in the PRA uses 6.4 percent dermal absorption because the handlers
and workers are exposed to the arsenic residue from the aqueous solution during mixing, loading, and handling
or are exposed to newly treated, or “wet’ wood which has arsenic residues on the surface of the wood).
For inhalation exposure, a default absorption factor of 100% is used. Route-to-route extrapolation is used to
estimate the exposed dose.
Q1* derived from a inhalation unit risk of 4.3 x 10 -3 (µg/m 3)-1. Unit risk= Q1* x 1/70 kg x 20 m 3/day x 1
mg/1,000 µg (EPA, 1989).
30
2.2
Inorganic Chromium Endpoint Selection
On August 28, 2001, the OPP’s Hazard Identification Assessment Review Committee (HIARC) evaluated
the toxicology data base of Cr(VI) and established the toxicological endpoints for occupational exposure
risk assessments. On October, 23-25 2001, the FIFRA Scientific Advisory Panel (SAP) met and discussed
some issues about the end points proposed by the HIARC. The conclusions related to inorganic arsenic are
summarized in Table 5.
2.2.1 Acute Reference Dose (aRfD)
An acute RfD value was not selected for inorganic chromium. Inorganic chromium is not
registered for any food uses and there are no existing tolerances. For inorganic chromium as
contained within CCA-treated wood, therefore, an acute RfD is not relevant to the exposures
from registered uses.
2.2.2 Chronic Reference Dose (cRfD)
The U.S. EPA has published a chronic RfD value for inorganic chromium (USEPA IRIS, 1998).
However, as with the acute RfD, there are no exposure scenarios relevant to the currently
registered uses of inorganic chromium, and specifically the registered uses in CCA-treated lumber.
If the Agency determines in the future that an aggregate assessment is needed for calculation of
risk from exposure to chromium in treated lumber and exposure in drinking water and/or food,
the chronic RfD value can be utilized.
2.2.3 Short-Term (1-30 days) and Intemediate-Term (30-180 days) Incidental Oral
Exposure
Based on the registered use of CCA-treated lumber for fencing and decking materials in
residential settings, incidental oral exposure to chromium is expected, based on potential ingestion
of soil contaminated with chromium as a result of leaching from wood, and from ingestion of
chromium residues from the palm as a result of direct dermal contact with treated wood. The
study selected for short- and intermediate-term incidental oral exposure is a developmental
toxicity study in the rabbit conducted by Tyl and submitted to the Agency under MRID #
42171201. The executive summary is shown below.
In a developmental toxicity study [ MRID 421712-01], artificially inseminated New Zealand
White rabbits (16 females/dose group) received aqueous chromic acid (55.0%) by gavage once
daily on gestation days 7 through 19 at dose levels of 0.0, 0.1, 0.5, 2.0, or 5.0 mg/kg/day in
deionized/distilled water.
Clinical signs of toxicity , including diarrhea, and slow, audible or labored breathing were
observed predominately in the 2.0 and 5.0 mg/kg/day groups. These signs were observed in
slightly higher incidence at the 2.0 mg/kg/day dose level than at the 5.0 mg/kg/day dose level.
31
However, the incidence and temporal occurrence of mortality (at 2.0 mg/kg/day, one doe died on
gestation day (GD) 28; at 5.0 mg/kg/day, 5 does died (one each on GD 10, 14, and two on GD
15) and the magnitude of decreased body weight gain during the dosing period (average weight
loss of 48 grams at 2.0 mg/kg/day and average weight loss of 140 grams at 5.0 mg/kg/day during
gestation days 7-19) were observed to occur in a dose-related fashion at 2.0 and 5.0 mg/kg/day.
Overall weight gain was decreased 24% at 2.0 mg/kg/day and 20% at 5.0 mg/kg/day. Food
efficiency was also observed to be significantly lower during the dosing period in the 5.0
mg/kg/day dose group. Cesarean section observations were unremarkable in this study at any
dose level tested. There were no significant treatment-related effects on the incidence of external,
visceral, or skeletal malformations in the offspring in this study.
The Maternal NOAEL = 0.5 [0.12] mg/kg/day and LOAEL = 2.0 [0.48] mg/kg/day (based
on the increased incidence of maternal mortality and decreased body weight gain ). The
Developmental NOAEL = 2.0 [0.48] mg/kg/day and LOAEL > 2.0 [>0.48] mg/kg/day based
on the lack of developmental effects at any dose level tested.
The developmental toxicity study in the rabbit was chosen for selection of the short-term and
intermediate-term incidental oral exposure endpoint. This study and endpoint is felt to be
appropriate for both short- and intermediate-term incidental oral exposures, based on the
occurrence of toxic effects after short-term dosing (mortality, clinical signs, weight loss), and
supporting data from the open literature showing similar effects after longer-term exposures at
similar dose levels. A study by Zhang and Li (1987) detailed toxic effects observed in 155 human
subjects exposed long-term to chromium in drinking water at a concentration of approximately 20
mg/L (USEPA IRIS, 1998), or 0.66 mg/kg/day. These effects included mouth sores, diarrhea,
stomach ache, indigestion, vomiting, and elevated white cell count. Although precise
concentrations of chromium in the water, exposure durations, and confounding factors were not
discussed in this paper, the data suggest gastrointestinal effects at a level of approximately 0.66
mg/kg/day. Thus, the choice of the NOAEL value of 0.5 mg/kg/day from the developmental
toxicity study in rabbits (a well-conducted multi-dose animal study) for the incidental oral
endpoint is felt to be protective of the gastrointestinal effects observed in humans at a similar
dose. The choice of this endpoint is also felt to be protective of the non-lethal effect observed in
humans based on a more severe effect observed in animals (i.e. mortality).
2.2.4 Dermal Absorption
For inorganic chromium, a dermal absorption value of 1.3% was selected, based upon the data of
Bagdon (1991). The executive summary of this study is presented below.
Sodium chromate (Cr(VI)) was applied to the skin of guinea pigs and the skin permeation was
determined by assay of 51Cr content present in the excreta (1.11%) and organs (0.19%) after 24
hours. In this study in guinea pigs, skin penetration of chromium amounted to 1.30% of the
applied dose after 24 hours. Using another in vivo method, a weighed amount of the agent was
patched to the skin of guinea pigs and the concentration followed by determination of the
remaining agent at the application site after different intervals. Skin penetration was concentration
32
dependent. The range used was 0.0048 to 1.689 M. Dermal penetration for hexavalent chromium
amounted to 2.6% of the applied dose of 0.0175 M/5 hours and 4.0% at 0.261 M/5 hours. At
0.261 M, the skin permeation rate was 700 mµM/cm2/hr. This procedure may overestimate skin
penetration because chromium present in the skin depot would be calculated as part of the
residual test material at the skin’s surface.
2.2.5 Short-, Intermediate-, and Long- term Dermal Exposure
The 1998 EPA IRIS document on chromium (VI) states that “chromium is one of the most
common contact sensitizers in males in industrialized countries and is associated with
occupational exposures to numerous materials and processes..” In addition, it is stated further
that “dermal exposure to chromium has been demonstrated to produce irritant and allergic contact
dermatitis.” The relative potency of this effect appears to differ between the (VI) and (III) species
of chromium. Bagdon (1991) collected skin hypersensitivity data for trivalent chromium
compounds in human subjects and concluded that the threshold level for evoking hypersensitivity
reactions from trivalent chromium compounds is approximately 50-fold higher than for hexavalent
chromium compounds.Nontheless, it is apparent that both forms of chromium cause
hypersensitivity reactions in humans.
It was determined by the Hazard Identification Assessment Review Committee (HIARC) of the
Office of Pesticide Programs that quantification of hazard from dermal exposure is not possible
for chromium, due to the significant dermal irritation and sensitization observed. Therefore, no
endpoints were determined by HIARC for hexavalent chromium from dermal exposures.
2.2.6 Inhalation Exposure (all durations)
Although chromium is not considered a volatile agent when present in soil, inhalation of soil dust
contaminated with chromium may present a potential inhalation risk given the significant irritant
properties of chromium and the potential for nasal deposition of the chemical after inhalation of
contaminated soil dust. Linberg, 1983 studied respiratory symptoms, lung function and changes in
nasal septum in 104 workers (85 males, 19 females exposed in chrome plating plants. Workers
were interviewed using a standard questionnaire for the assessment of nose, throat and chest
symptoms. Nasal inspections and pulmonary function testing were performed as part of the study.
The median exposure time for the entire group of exposed subjects (104) in the study was 4.5
years (0.1-36 years). A total of 43 subjects exposed almost exclusively to chromic acid
experienced a mean exposure of 2.5 years (0.2-23.6 years). The subjects exposed almost
exclusively to chromic acid were divided into a low exposure group (8-hr TWA below 0.002
mg/m3, N=19) and a high-exposure group (8-hr TWA above 0.002 mg/m 3, N=24). Exposure
measurements using personal air samplers were performed for 84 subjects in the study on 13
different days. Exposure for the remaining workers 20 workers was assumed to be similar to that
measured for workers in the same area. Nineteen office employees were used as controls for nose
and throat symptoms. A group of 119 auto mechanics whose lung function had been evaluated by
33
similar techniques was selected as controls for lung function measurements. Smoking habits of
workers were evaluated as part of the study.
At mean exposures below 0.002 mg/m3, 4/19 workers from the low-exposure group experienced
subjective nasal symptoms. Atrophied nasal mucosa were reported in 4/19 subjects from this
group and 11/19 had smeary and crusty and septal mucosa, which was statistically higher than the
controls. No one exposed to levels below 0.001 mg/m 3 complained of subjective symptoms. At
mean concentrations of 0.002 mg/m 3 or above, approximately 1/3 of the subjects had reddened,
smeary or crusty nasal mucosa. Atrophy was seen in 8/24 workers, which was significantly
different from controls. Eight subjects had ulcerations in the nasal mucosa and 5 had perforations
of the nasal septum. Atrophied nasal mucosa was not observed in any of the 19 controls, but
smeary and crusty septal mucosa occurred in 5/19 controls.
Short-term effects on pulmonary function were evaluated by comparing results of tests taken on
Monday and Thursday among exposed groups and controls. No significant changes were seen in
the low-exposure group or the control group. Non-smokers in the high-exposure group
experienced significant differences in pulmonary function measurements from the controls, but the
results were within normal limits.
The authors concluded that 8 hour exposure to chromic acid above 0.002 mg/m 3 may cause a
transient decrease in lung function, and that short-term exposure to greater than 0.002 mg/m3
may cause ulceration and perforation. Based on the result of this study, a LOAEL of 0.002 mg/m 3
can be identified for incidence of nasal septum atrophy following exposure to chromic acid mists
in chrome plating facilities. Therefore, the LOAEL of continuous exposure of 0.002 mg/m 3 was
based on ulcerations, perforations of the nasal septum and pulmonary function changes. A MOE
of 100 selected (3x to extrapolate from LOAEL to NOAEL, 3X to account for the uncertainty
associated with using an epidemiological study and 10X for intraspecies extrapolation). The 100
mg/m3 can not be considered as NOAEL because it is just a level reported with no subjective
symptoms.
2.2.7 Carcinogenicity
The cancer endpoint for inhalation exposure is classified as group A (known human carcinogen)
with an inhalation unit risk of 1.2x10-2 (?g/m3)-1 (Table 5). Human carcinogenicity by the oral
route of exposure cannot be determined and chromium is classified as group D.
34
Table 5.
Toxicological Endpoints for Assessing Occupational Exposures/Risks to Chromium (VI)
EXPOSURE
SCENARIO
DOSE
(mg/kg/day)
ENDPOINT
Acute Dietary
This risk assessment is not required.
Chronic Dietary
This risk assessment is not required.
Incidental Shortand IntermediateTerm Oral
(a)
NOAEL= 0.5of
chromic acid
[0.12 of Cr(VI)]
MOE = 100
Dermal Exposure (b)
(All Durations)
based on the increased
incidence of maternal
mortality and decreased body
weight gain at LOAEL of 2.0
[0.48]
STUDY
Developmental/Rabbit
Tyl, 1991
Because dermal irritation and dermal sensitization are the primary concern
through the dermal exposure route, no toxicological end-point is selected for use
in assessing dermal exposure risks to chromium.
Inhalation
Exposure
(All Durations)
(a)
LOAEL= 0.002
mg/m3; (or 2.3 x 10 -4
mg/kg/day)
MOE = 100
Carcinogenicity Inhalation
Q1* = 40.6
(mg/kg/day) -1 (c)
nose and throat symptoms
observed at the 0.002 mg/m 3
level
Lung tumors
Linberg and
Hedenstierna, 1983.
IRIS
(Inhalation Unit
Risk)
Note:
(a).
(b).
(c)
MOE = Margin of Exposure; NOAEL = No observed adverse effect level; and LOAEL = Lowest observed
adverse effect level.
The dermal absorption factor for Cr(VI) = 1.3% for handler dermal contact with chromated arsenical
pesticides.
The inhalation Q1* is 1.16 x 10-2 (µg/m 3)-1 which can also be expressed as 0.0116 m3/?g.. To convert the air
concentration to a dose to yield units of kg-day/mg or (mg/kg/day) -1 the unit risk is expressed
mathematically as 0.0116 m3/?g x day/20 m3 x 1000 ?g/mg x 70 kg = 40.6 (mg/kg/day) -1 (EPA, 1989).
35
3.0
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Toxicology 21:83-88
Freeman, G.B., Schoof, R.A., Ruby, M.V., Davis, A.O., Dill, J.A., Liao, S.C., Lapin, C.A., and
Bergstrom, P.D. 1995. Bioavailability of Arsenic in Soil and House Dust Impacted by
Smelter Activities Following Oral Administration in Cynomologus Monkeys.
Fundamental and Applied Toxicology 28:215-222
Gibson DP, Brauninger R, Shaffi HS, et al. 1997. Induction of micronuclei in Syrian hamster
embryocells: comparison of results in the SHE cell transformation assay for national
toxicology program test chemicals. Mutat Res 392(1-2):61-70.
Groen, K., Vaesen, H.A.G., Klest, J.I.G. deBar, J.L.M., von Ooik, T. Timmerman, A. and Vlug,
R.G. 1993. Bioavailability of Inorganic Arsenic from Bog Ore-Containing Soil in the
Dog. Environmental Health Perspective 102: 182-184.
37
Henderson RF, Rebar AH, Pickrell JA, et al. 1979. Early damage indicators in the lung. III.
Biochemical and cytological response of the lung to inhaled metal salts. Toxicol Appl
Pharmacol 50:123-136.
Hopenhayn-Rich et al., 1998: Lung and Kidney Cancer Mortality Associated with Arsenic in
Drinking Water in Cordoba, Argentina. Epidemiology 27: 561-569.
Hopenhayn-Rich et al., 2000: Chronic Arsenic Exposure and Risk of Infant Mortality in Two
Areas of Chile. Env. Hlth. Perspec. 108: 667-673, July 2000.
Hopenhayn, C, Ferreccio, C, Browning, SR, Huang, B. et al. (2003) Arsenic Exposure from
Drinking Water and Birth Weight. Epidemiology 14:593-602.
Hueper, WC; Payne, WW. (1962) Experimental studies in metal carcinogenesis-Chromium,nickel, iron, arsenic. Arch Environ Health 5:445-462.
International Agency for Research on Cancer (IARC). 1990. IARC monographs on the evaluation
of the carcinogenic risk of chemicals to humans. Vol. 49. Some metals and metallic
compounds. Lyon, France: World Health Organization.
IRIS. 2000. Chromium VI. Integrated Risk Information System. U.S. Environmental
ProtectionAgency, Office of Health and Environmental Assessment, Environmental
Criteria and Assessment Office, Cincinnati, OH.
Ivankovic, S; Preussman, R. 1975. Absence of toxic and carcinogenic effects after administrations
of high doses of chronic oxide pigment in subacute and long term feeding experiments in
rats. Food Cosmet Toxicol 13:347-351.
Jennette KW. 1982. Microsomal reduction of the carcinogen chromate produced chromium(V). J
Am Chem Soc 104:874-875.
Junaid M, Murthy RC, Saxena DK. 1996a. Embryo- and fetotoxicity of chromium in
pregestationally exposed mice. Bull Environ Contam Toxicol 57:327-334.
Kanojia RK, Junaid M, Murthy RC. 1996. Chromium induced teratogenicity in female rat.
ToxicolLett 89:207-213.
Kenyon, E.M. and Hughes, M.F. 2001.: A concise review of the toxicity and carcinogenicity of
dimethylarsinic acid. Toxicology 160: 227-236.
38
Kochhar TS, Howard W, Hoffman S, et al. 1996. Effect of trivalent and pentavalent arsenic in
causing chromosome alterations in cultured Chinese hamster ovary (CHO) cells. Toxicol
Lett 84(1):37-42.
Lerman S, Clarkson TW, Gerson RJ. 1983. Arsenic uptake and metabolism by liver cells is
dependent on arsenic oxidation state. Chem Biol Interact 45:401-406.
Larramendy ML, Popescu NC, DiPaolo J. 1981. Induction by inorganic metal salts of sister
chromatid exchanges and chromosome aberrations in human and Syrian hamster strains.
Environ Mutagen 3:597-606.
Lebow, S. 1996. Leaching of Wood Preservative Components and their Mobility in the
Environment- Summary of Pertinent Literature. Gen. Tech. Rep. FPL-GTR-93. Madison,
WI: U.S. Department of Agriculture, Forest Service, Forest Products Laboratory, 36 p.
Lee, T-C, et al. 1985. Comparison of arsenic-induced cell transformation, cytotoxicity, mutation,
and cytogenetic effects in Syrian hamster embryo cells in culture. Carcinogenesis 6(10):
1421-1426.
Levy, LS; Venitt, S. 1975. Carcinogenic and mutagenic activity of chromium-containing
materials. Br J Cancer 32:254-255.
Levy, LS; Martin, PA. 1983. The effects of a range of chromium-containing materials on rat lung.
Dye Color Manufacturers Association.
Maruyama, Y.(1982): The health effect of mice given oral administration of trivalent and
hexavalent chromium over a long term. Acta Scholae Medicinalis Universitatis in Gifu
31:24-36.
Mass, M.J. et al. 2001.: Methylated Trivalent Arsenic Species are Genotoxic. Chem. Res.
Toxicol. 14: 355-361.
Mizuta, N, Mizuta, et al. 1956. An Outbreak of Acute Arsenic Poisoning Caused by ArsenicContaining Soy-Sauce (Shoyu). A Clinical Report of 220 Cases. Bull Yamaguchi Med
Sch 4(2-3):131-149.
Moore MM, Harrington-Brock K, Doerr CL. 1997. Relative genotoxic potency of arsenic and its
methylated metabolites. Mutat Res 386(3):279-290.
Morales, K. H.; Ryan, L.; Kuo, T.; Wu, M.; and Chen, C.. 2000. Risk of Internal Cancers from
Arsenic in Drinking Water. Environ. Health Perspect 108:655-661.
National Research Council: Arsenic in Drinking Water: 2001 Update. September, 2001, National
Academy Press, Washington, D.C.
39
National Toxicology Program (NTP). 1996. Final report on the reproductive toxicity of
potassium dichromate (hexavalent)(CAS No. 7778-50-9) administered in diet to SD rats.
Dec. 16, 1996. U.S. Department of Commerce, National Technical Information Service,
PB97125355.
National Toxicology Program (NTP). 1997a. Final report on the reproductive toxicity of
potassium dichromate (hexavalent) (CAS No. 7778-50-9) administered in diet to BALB/C
mice. Jan 10, 1997. U.S. Department of Commerce, National Technical Information
Service, PB97125363.
NTP, Public Health Service, U.S. Department of Health and Human Services. 1997. Final report.
Potassium dichromate (hexavalent): reproductive assessment by continuous breeding when
administered to BALB/c mice in the diet. February 18, 1997. Available from: National
Institute of Environmental Health Sciences, Research Triangle Park, NC.
NRC (National Research Council). 1999. Arsenic in Drinking Water. National Academy Press,
Washington, D.C.
Oberly TJ, Piper CE, McDonald DS. 1982. Mutagenicity of metal salts in the L5178Y mouse
lymphoma assay. J Toxicol Environ Health 9:367-376.
Rossman, T.G. et al. 1980.: Absence of arsenite mutagenicity in E. coli and Chinese hamster cells.
Environ. Mut. 2: 371-379.
Sayato Y, Nakamuro K, Matsui S, et al. 1980. Metabolic fate of chromium compounds. I.
Comparative behavior of chromium in rat administered with Na251CrO4 and 51CrCl3. J
Pharm Dyn 3:17-23.
Schroeder, HA; Balassa, JJ; Vinton, WH, Jr. 1965. Chromium, cadmium and lead in rats: effects
on lifespan, tumors, and tissue levels. J Nutr 86:51-66.
Suzuki Y, Fukuda K. 1990. Reduction of hexavalent chromium by ascorbic acid and glutathione
with special reference to the rat lung. Arch Toxicol 64:169-176.
Towill, LE; Shriner, CR; Drury, JS; et al. 1978. Reviews of the environmental effects of
pollutants. III. Chromium. Prepared by the Health Effects Research Laboratory, Office
ofResearch and Development, U.S. Environmental Protection Agency, Cincinnati, OH.
Report No. ORNL/EIS-80. EPA 600/1-78-023. NTIS PB 282796.
Trivedi B, Saxena DK, Murthy RC, et al. 1989. Embryotoxicity and fetotoxicity of orally
administered hexavalent chromium in mice. Reprod Toxicol 3:275-278.
40
Tseng, W.P., H.M. Chu, S.W. How, J.M. Fong, C.S. Lin, and S. Yeh. 1968. Prevalence of skin
cancer in an endemic area of chronic arsenicism in Taiwan. J. Natl. Cancer Inst.
40:453-463.
Tseng W-P. 1977. Effects and dose-response relationships of skin cancer and Blackfoot disease
with arsenic. Environ Health Perspect 19:109-119.
USEPA. Bioavailability of Arsenic and Lead in Environmental Substrates. 1. Results of an Oral
Dosing Study of Immature Swine. Superfund/Office of Environmental Assessment,
Region 10, EPA 910/R-96-002, 1996.
USEPA. 2001. National Primary Drinking Water Regulation; Arsenic and Clarifications to
Compliance and New Source Contaminants Monitoring; Final Rule. Federal Register.
Vol. 66, No. 14. p. 6975, January 22, 2001.
USEPA Region 8, 2001: Derivation of Acute and Subchronic Oral Reference Doses for Inorganic
Arsenic.
USEPA, IRIS, Chromium (VI), 1998; CASRN 18540-29-9, 9/3/1998 .
Waalkes, MP; Ward, JM; Liu, J. and Diawan, BA. 2003. Transplacental carcinogenicity of
Inorganic Arsenic in the Drinking Water: Induction of Hepatic, Ovarian, Pulmary, and
Adrenal Tumors in Mice. Toxicology and Applied Pharmacology: 186:7-17.
Wiegand, HJ; Ottenwalder, H; Bolt, HM. 1985. Fast uptake kinetics in vitro of 51 Cr(VI) by red
blood cells of man and rat. Arch Toxicol 57:31-34.
Wester, R.C., Maibach, H.I., Sedik, L. Melendres, J., and Wader, M. 1993. In Vivo and in Vitro
Percutaneous Absorption and Skin Decontamination of Arsenic From Water and Soil.
Fundamental and Applied Toxicology 20:336-340
Williams, T.W. : Rawlins, B.G.; Smith, B.; and Breward, N. 1998. In-Vitro Determination of
Arsenic Bioavailability in Contaminated Soil and Mineral Benefication Waste from Ron
Phibun, Southern Thailand: A Basis for Improved Human Risk Assessment.
Environmental Geochemistry and Health: 20
Witmer, C.M, Harris R and Shupack SI. 1991. Oral bioavailability of chromium from a specific
site. Environ Health Perspect 92:105-110.
Zahid,Z.R., Al-Hakkak ZS, Kadhim AHH, et al. 1990. Comparative effects of trivalent and
hexavalent chromium on spermatogenesis of the mouse. Toxicol Environ Chem 25:131136.
41
Attachment 1
US EPA’s Risk Assessment for Arsenic in Drinking Water
Converting from ppb and (ppb)-1
to :g/kg/d and (:g/kg/d)-1
Suppose a person consumes A ppb (:g/L) of arsenic in drinking water. They weigh K kg
and drink C L/d of water. Then in :g/kg/d, their exposure is
A
ug C L / d AC ug
⋅
=
K kg ⋅ d
L K kg
where the liters have cancelled from the numerator and denominator.
On the risk side, suppose that the risk slope is S per ppb (ppb-1). For the same person as
above drinking C L/d of water and weighing K kg, the risk per :g/kg/d is
S K kg SK
⋅
=
ug/L C L /d C ug/kg/d
Again the liters cancel. This is just simple algebra, there’s nothing more to it.
3.0
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Perspec. 92: 111-119.
Bertolero F, Pozzi G, Sabbioni E, et al. 1987. Cellular uptake and metabolic reduction of
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Bryson WG, Goodall CM. 1983. Differential toxicity and clearance kinetics of chromium(III) or
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Chowdhury AR, Mitra C. 1995. Spermatogenic and steroidogenic impairment after chromium
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Chromium in the Environment. Critical Rev. in Environmental Science and Technology
29(1): 1-46.
De Flora S, Badolati GS, Serra D, et al. 1987a. Circadian reduction of chromium in the gastric
environment. Mutat Res 192:169-174.
Donaldson DL, Smith CC, and Yunice AA. 1984. Renal excretion of chromium-51 chloride in the
dog. Am J Physiol 246:F870-F878.
Donaldson RM and Barreras RF. 1966. Intestinal absorption of trace quantities of chromium. J
Lab Clin Med 68:484-493.
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234/Wednesday, Dec. 8, 1993/Notices, p. 64580-64582]
Fishbein L. 1981. Sources, transport and alterations of metal compounds: An overview. I.
Arsenic,beryllium, cadmium, chromium and nickel. Environ Health Perspect 40:43-64.
Franzblau, A. and Lilis, R. 1989. Acute Arsenic Intoxication from Environmental Arsenic
Exposure. Archives of Envir. Health 44(6). 385-390.
Freeman, GB., Johnson, J.D., Killinger, J.M., Liao, S.C., Davis, A.O., Ruby, M.V., Chaney, R.L.,
Lovre, S.C., and Bergstrom, P.D. 1993. Bioavailability of Arsenic in Soil Impacted by
Smelter Activities Following Oral Administration in Rabbits. Fundamental and Applied
Toxicology 21:83-88
Freeman, G.B., Schoof, R.A., Ruby, M.V., Davis, A.O., Dill, J.A., Liao, S.C., Lapin, C.A., and
Bergstrom, P.D. 1995. Bioavailability of Arsenic in Soil and House Dust Impacted by
Smelter Activities Following Oral Administration in Cynomologus Monkeys.
Fundamental and Applied Toxicology 28:215-222
Gibson DP, Brauninger R, Shaffi HS, et al. 1997. Induction of micronuclei in Syrian hamster
embryocells: comparison of results in the SHE cell transformation assay for national
toxicology program test chemicals. Mutat Res 392(1-2):61-70.
Groen, K., Vaesen, H.A.G., Klest, J.I.G. deBar, J.L.M., von Ooik, T. Timmerman, A. and Vlug,
R.G. 1993. Bioavailability of Inorganic Arsenic from Bog Ore-Containing Soil in the
Dog. Environmental Health Perspective 102: 182-184.
31
Henderson RF, Rebar AH, Pickrell JA, et al. 1979. Early damage indicators in the lung. III.
Biochemical and cytological response of the lung to inhaled metal salts. Toxicol Appl
Pharmacol 50:123-136.
Hopenhayn-Rich et al., 1998: Lung and Kidney Cancer Mortality Associated with Arsenic in
Drinking Water in Cordoba, Argentina. Epidemiology 27: 561-569.
Hopenhayn-Rich et al., 2000: Chronic Arsenic Exposure and Risk of Infant Mortality in Two
Areas of Chile. Env. Hlth. Perspec. 108: 667-673, July 2000.
Hueper, WC; Payne, WW. (1962) Experimental studies in metal carcinogenesis-Chromium,nickel, iron, arsenic. Arch Environ Health 5:445-462.
International Agency for Research on Cancer (IARC). (1990) IARC monographs on the
evaluation of the carcinogenic risk of chemicals to humans. Vol. 49. Some metals and
metallic compounds. Lyon, France: World Health Organization.
IRIS. 2000. Chromium VI. Integrated Risk Information System. U.S. Environmental
ProtectionAgency, Office of Health and Environmental Assessment, Environmental
Criteria and Assessment Office, Cincinnati, OH.
Ivankovic, S; Preussman, R. (1975) Absence of toxic and carcinogenic effects after
administrations of high doses of chronic oxide pigment in subacute and long term feeding
experiments in rats. Food Cosmet Toxicol 13:347-351.
Jennette KW. 1982. Microsomal reduction of the carcinogen chromate produced chromium(V). J
Am Chem Soc 104:874-875.
Junaid M, Murthy RC, Saxena DK. 1996a. Embryo- and fetotoxicity of chromium in
pregestationally exposed mice. Bull Environ Contam Toxicol 57:327-334.
Kanojia RK, Junaid M, Murthy RC. 1996. Chromium induced teratogenicity in female rat.
ToxicolLett 89:207-213.
Kenyon, E.M. and Hughes, M.F. (2001): A concise review of the toxicity and carcinogenicity of
dimethylarsinic acid. Toxicology 160: 227-236.
Kochhar TS, Howard W, Hoffman S, et al. 1996. Effect of trivalent and pentavalent arsenic in
causing chromosome alterations in cultured Chinese hamster ovary (CHO) cells. Toxicol
Lett 84(1):37-42.
Lerman S, Clarkson TW, Gerson RJ. 1983. Arsenic uptake and metabolism by liver cells is
dependent on arsenic oxidation state. Chem Biol Interact 45:401-406.
32
Larramendy ML, Popescu NC, DiPaolo J. 1981. Induction by inorganic metal salts of sister
chromatid exchanges and chromosome aberrations in human and Syrian hamster strains.
Environ Mutagen 3:597-606.
Lebow, S. (1996): Leaching of Wood Preservative Components and their Mobility in the
Environment- Summary of Pertinent Literature. Gen. Tech. Rep. FPL-GTR-93. Madison,
WI: U.S. Department of Agriculture, Forest Service, Forest Products Laboratory, 36 p.
Lee, T-C, et al. (1985): Comparison of arsenic-induced cell transformation, cytotoxicity,
mutation, and cytogenetic effects in Syrian hamster embryo cells in culture.
Carcinogenesis 6(10): 1421-1426.
Levy, LS; Venitt, S. (1975) Carcinogenic and mutagenic activity of chromium-containing
materials. Br J Cancer 32:254-255.
Levy, LS; Martin, PA. (1983) The effects of a range of chromium-containing materials on rat
lung. Dye Color Manufacturers Association.
Maruyama, Y.(1982): The health effect of mice given oral administration of trivalent and
hexavalent chromium over a long term. Acta Scholae Medicinalis Universitatis in Gifu
31:24-36.
Mass, M.J. et al. (2001): Methylated Trivalent Arsenic Species are Genotoxic. Chem. Res.
Toxicol. 14: 355-361.
Mizuta, N, Mizuta, et al. 1956. An Outbreak of Acute Arsenic Poisoning Caused by ArsenicContaining Soy-Sauce (Shoyu). A Clinical Report of 220 Cases. Bull Yamaguchi Med
Sch 4(2-3):131-149.
Moore MM, Harrington-Brock K, Doerr CL. 1997. Relative genotoxic potency of arsenic and its
methylated metabolites. Mutat Res 386(3):279-290.
National Research Council: Arsenic in Drinking Water: 2001 Update. September, 2001, National
Academy Press, Washington, D.C.
National Toxicology Program (NTP). 1996. Final report on the reproductive toxicity of
potassium dichromate (hexavalent)(CAS No. 7778-50-9) administered in diet to SD rats.
Dec. 16, 1996. U.S. Department of Commerce, National Technical Information Service,
PB97125355.
National Toxicology Program (NTP). 1997a. Final report on the reproductive toxicity of
potassium dichromate (hexavalent) (CAS No. 7778-50-9) administered in diet to BALB/C
33
mice. Jan 10, 1997. U.S. Department of Commerce, National Technical Information
Service, PB97125363.
NTP, Public Health Service, U.S. Department of Health and Human Services. (1997) Final report.
Potassium dichromate (hexavalent): reproductive assessment by continuous breeding when
administered to BALB/c mice in the diet. February 18, 1997. Available from: National
Institute of Environmental Health Sciences, Research Triangle Park, NC.
NRC (National Research Council). 1999. Arsenic in Drinking Water. National Academy Press,
Washington, D.C.
Oberly TJ, Piper CE, McDonald DS. 1982. Mutagenicity of metal salts in the L5178Y mouse
lymphoma assay. J Toxicol Environ Health 9:367-376.
Roberts, S.M.; Welmar, W.R.; Venson, J.R.; Munson, J.W.; and Bergeron. Measurement of
Arsenic Bioavailability from Soils Using a Primate Model. Abstract.
Rossman, T.G. et al. (1980): Absence of arsenite mutagenicity in E. coli and Chinese hamster
cells. Environ. Mut. 2: 371-379.
Sayato Y, Nakamuro K, Matsui S, et al. 1980. Metabolic fate of chromium compounds. I.
Comparative behavior of chromium in rat administered with Na251CrO4 and 51CrCl3. J
Pharm Dyn 3:17-23.
Schroeder, HA; Balassa, JJ; Vinton, WH, Jr. (1965) Chromium, cadmium and lead in rats: effects
on lifespan, tumors, and tissue levels. J Nutr 86:51-66.
Suzuki Y, Fukuda K. 1990. Reduction of hexavalent chromium by ascorbic acid and glutathione
with special reference to the rat lung. Arch Toxicol 64:169-176.
Towill, LE; Shriner, CR; Drury, JS; et al. (1978) Reviews of the environmental effects of
pollutants. III. Chromium. Prepared by the Health Effects Research Laboratory, Office
ofResearch and Development, U.S. Environmental Protection Agency, Cincinnati, OH.
Report No. ORNL/EIS-80. EPA 600/1-78-023. NTIS PB 282796.
Trivedi B, Saxena DK, Murthy RC, et al. 1989. Embryotoxicity and fetotoxicity of orally
administered hexavalent chromium in mice. Reprod Toxicol 3:275-278.
Tseng, W.P., H.M. Chu, S.W. How, J.M. Fong, C.S. Lin, and S. Yeh. 1968. Prevalence of skin
cancer in an endemic area of chronic arsenicism in Taiwan. J. Natl. Cancer Inst.
40:453-463.
34
Tseng W-P. 1977. Effects and dose-response relationships of skin cancer and Blackfoot disease
with arsenic. Environ Health Perspect 19:109-119.
USEPA. Relative Bioavailability of Arsenic in Mining Wastes, Region 8, Document Control No.
4500-88-AORH, 1997.
USEPA. Bioavailability of Arsenic and Lead in Environmental Substrates. 1. Results of an Oral
Dosing Study of Immature Swine. Superfund/Office of Environmental Assessment,
Region 10, EPA 910/R-96-002, 1996.
USEPA Region 8, 2001: Derivation of Acute and Subchronic Oral Reference Doses for Inorganic
Arsenic.
U.S. EPA, IRIS, Chromium (VI), 1998; CASRN 18540-29-9, 9/3/1998 .
Wiegand, HJ; Ottenwalder, H; Bolt, HM. (1985) Fast uptake kinetics in vitro of 51 Cr(VI) by red
blood cells of man and rat. Arch Toxicol 57:31-34.
Wester, R.C., Maibach, H.I., Sedik, L. Melendres, J., and Wader, M. 1993. In Vivo and in Vitro
Percutaneous Absorption and Skin Decontamination of Arsenic From Water and Soil.
Fundamental and Applied Toxicology 20:336-340
Williams, T.W. : Rawlins, B.G.; Smith, B.; and Breward, N. 1998. In-Vitro Determination of
Arsenic Bioavailability in Contaminated Soil and Mineral Benefication Waste from Ron
Phibun, Southern Thailand: A Basis for Improved Human Risk Assessment.
Environmental Geochemistry and Health: 20
Witmer, C.M, Harris R and Shupack SI. 1991. Oral bioavailability of chromium from a specific
site. Environ Health Perspect 92:105-110.
Zahid,Z.R., Al-Hakkak ZS, Kadhim AHH, et al. 1990. Comparative effects of trivalent and
hexavalent chromium on spermatogenesis of the mouse. Toxicol Environ Chem 25:131136.
35
Appendix B
Risk Spreadsheets
Table 1. Probabilistic Estimates of Cancer Risks for Children Exposed to Arsenic Dislodgeable Residues and Contaminated Soil from Treated Wood Playsets and Residential Decks
in Warm Climate (separated by children with and without decks) [Based on LADDs in Table 14 from the SHEDS-Wood Document.]*
Pathway
Deck
n
mean
std
p50
min
p05
p25
p75
p95
p99
max
Total Dose
Playset Total Dose
Playset Surf Inges-HandToMouth Dose
Playset Soil Inges-Direct Dose
Playset Surf Derm Dose
Playset Soil Derm Dose
0
0
0
0
0
0
728
728
728
728
728
728
2.3E-05
2.3E-05
1.4E-05
2.3E-06
6.5E-06
4.3E-07
4.4E-05
4.4E-05
3.2E-05
4.2E-06
1.2E-05
5.3E-07
1.1E-05
1.1E-05
5.3E-06
7.7E-07
3.0E-06
2.6E-07
1.0E-07
1.0E-07
1.0E-08
9.6E-10
1.7E-08
4.0E-09
1.7E-06
1.7E-06
4.2E-07
4.4E-08
3.3E-07
3.2E-08
4.9E-06
4.9E-06
1.9E-06
2.2E-07
1.3E-06
1.3E-07
2.5E-05
2.5E-05
1.3E-05
2.4E-06
6.7E-06
5.3E-07
8.3E-05
8.3E-05
5.4E-05
1.0E-05
2.3E-05
1.4E-06
2.4E-04
2.4E-04
1.7E-04
2.0E-05
7.1E-05
2.3E-06
4.9E-04
4.9E-04
3.8E-04
4.0E-05
1.1E-04
5.8E-06
Total Dose
Playset Total Dose
Playset Surf Inges-Hand To Mouth Dose
Playset Soil Inges-Direct Dose
Playset Surf Derm Dose
Playset Soil Derm Dose
Deck Total Dose
Deck Surf Inges-HandToMouth Dose
Deck Soil Inges-Direct Dose
Deck Surf Derm Dose
Deck Soil Derm Dose
1
1
1
1
1
1
1
1
1
1
1
738
738
738
738
738
738
738
738
738
738
738
4.2E-05
2.0E-05
1.1E-05
2.4E-06
5.7E-06
4.8E-07
2.2E-05
1.3E-05
3.4E-07
8.1E-06
7.7E-08
5.9E-05
3.0E-05
2.2E-05
4.4E-06
8.9E-06
7.7E-07
3.5E-05
2.2E-05
8.4E-07
1.6E-05
1.2E-07
2.3E-05
1.1E-05
4.5E-06
7.6E-07
2.6E-06
3.0E-07
1.0E-05
5.7E-06
8.6E-08
3.7E-06
3.5E-08
9.1E-07
4.3E-08
1.4E-08
5.6E-10
7.2E-09
1.5E-09
1.0E-08
2.7E-09
3.2E-12
7.5E-09
5.0E-13
3.7E-06
1.5E-06
3.1E-07
6.8E-08
2.5E-07
4.4E-08
1.2E-06
5.0E-07
3.0E-09
3.8E-07
2.0E-09
1.1E-05
4.7E-06
1.8E-06
2.9E-07
1.0E-06
1.4E-07
4.6E-06
2.4E-06
2.2E-08
1.5E-06
1.3E-08
4.7E-05
2.2E-05
1.2E-05
2.5E-06
6.5E-06
5.7E-07
2.4E-05
1.4E-05
2.7E-07
8.8E-06
9.6E-08
1.4E-04
6.7E-05
4.5E-05
1.0E-05
2.2E-05
1.4E-06
7.7E-05
4.7E-05
1.3E-06
2.9E-05
2.7E-07
3.1E-04
1.4E-04
9.6E-05
2.4E-05
4.8E-05
3.0E-06
1.8E-04
1.2E-04
4.7E-06
6.4E-05
6.0E-07
6.1E-04
3.7E-04
2.7E-04
4.0E-05
1.0E-04
1.6E-05
5.1E-04
2.0E-04
1.1E-05
3.1E-04
1.2E-06
* Cancer Risks calculated by multiplying the slope factor (Q1*) times the LADD reported in Table 14 of the SHEDS-Wood document.
The slope factor (Q1*) of 3.67 (mg/kg/day)-1 is used in this assessment.
Table 2. Probabilistic Estimates of Cancer Risks for Children Exposed to Arsenic Dislodgeable Residues and Contaminated Soil from Treated Wood Playsets and Residential
Decks in Cold Climate (separated by children with and without decks) [Based on LADDs in Table 15 from the SHEDS-Wood Document.]*
Pathway
Deck
n
mean
std
p50
min
p05
p25
p75
p95
p99
max
Total Dose
Playset Total Dose
Playset Surf Inges-HandToMouth Dose
Playset Soil Inges-Direct Dose
Playset Surf Derm Dose
Playset Soil Derm Dose
0
0
0
0
0
0
744
744
744
744
744
744
1.2E-05
1.2E-05
1.0E-05
1.0E-07
1.5E-06
7.7E-09
1.8E-05
1.8E-05
1.6E-05
3.4E-07
2.0E-06
1.8E-08
5.4E-06
5.4E-06
4.4E-06
1.8E-08
7.7E-07
2.4E-09
1.9E-08
1.9E-08
1.8E-08
1.0E-12
1.3E-09
5.5E-13
6.2E-07
6.2E-07
4.6E-07
6.5E-10
9.2E-08
1.2E-10
2.4E-06
2.4E-06
1.8E-06
4.6E-09
3.5E-07
8.9E-10
1.3E-05
1.3E-05
1.0E-05
6.7E-08
1.8E-06
6.6E-09
4.5E-05
4.5E-05
3.9E-05
4.2E-07
5.4E-06
3.1E-08
8.9E-05
8.9E-05
7.8E-05
1.4E-06
9.5E-06
8.7E-08
2.0E-04
2.0E-04
1.9E-04
4.9E-06
2.0E-05
2.6E-07
Total Dose
Playset Total Dose
Playset Surf Inges-HandToMouth Dose
Playset Soil Inges-Direct Dose
Playset Surf Derm Dose
Playset Soil Derm Dose
Deck Total Dose
Deck Surf Inges-HandToMouth Dose
Deck Soil Inges-Direct Dose
Deck Surf Derm Dose
Deck Soil Derm Dose
1
1
1
1
1
1
1
1
1
1
1
718
718
718
718
718
718
718
718
718
718
718
2.2E-05
1.0E-05
8.8E-06
1.2E-07
1.4E-06
1.0E-08
1.2E-05
9.7E-06
3.2E-07
1.8E-06
2.3E-08
3.4E-05
1.6E-05
1.5E-05
6.2E-07
1.8E-06
3.1E-08
2.1E-05
1.8E-05
8.8E-07
3.2E-06
3.0E-08
1.1E-05
4.7E-06
3.8E-06
2.2E-08
7.2E-07
3.1E-09
5.4E-06
4.2E-06
9.2E-08
8.7E-07
1.3E-08
2.7E-07
1.4E-07
8.9E-08
1.2E-11
1.0E-08
3.5E-12
1.9E-08
1.5E-08
5.1E-11
3.1E-09
1.9E-11
1.5E-06
5.5E-07
3.5E-07
7.5E-10
7.8E-08
1.8E-10
6.7E-07
3.8E-07
4.4E-09
8.6E-08
9.7E-10
5.2E-06
2.0E-06
1.6E-06
6.0E-09
3.0E-07
1.0E-09
2.6E-06
1.7E-06
2.4E-08
3.8E-07
5.1E-09
2.6E-05
1.2E-05
9.9E-06
7.9E-08
1.7E-06
7.7E-09
1.3E-05
1.1E-05
2.6E-07
2.0E-06
2.8E-08
7.8E-05
3.8E-05
3.4E-05
4.0E-07
5.1E-06
4.2E-08
4.3E-05
3.8E-05
1.4E-06
6.5E-06
8.1E-08
1.6E-04
7.0E-05
6.3E-05
1.5E-06
8.9E-06
1.2E-07
8.5E-05
7.4E-05
3.7E-06
1.2E-05
1.6E-07
3.8E-04
2.0E-04
1.9E-04
1.5E-05
1.9E-05
6.0E-07
3.3E-04
2.7E-04
1.7E-05
5.9E-05
2.9E-07
* Cancer Risks calculated by multiplying the slope factor (Q1*) times the LADD reported in Table 15 of the SHEDS-Wood document.
The slope factor (Q1*) of 3.67 (mg/kg/day)-1 is used in this assessment.
Table 3. Probabilistic Estimates of Intermediate-Term MOEs for Children Exposed to Arsenic Dislodgeable Residues and Contaminated Soil from Treated Wood Playsets and
Residential Decks in Warm Climate (separated by children with and without decks) [Based on intermediate-term ADDs in Table 16 from the SHEDS-Wood Document.]*
Pathway
Deck
n
mean
std
p50
min
p05
p25
p75
p95
p99
max
Total Dose
Playset Total Dose
Playset Surf Inges-HandToMouth Dose
Playset Soil Inges-Direct Dose
Playset Surf Derm Dose
Playset Soil Derm Dose
0
0
0
0
0
0
715
715
715
715
715
715
849
849
1419
7318
3258
3.3E+04
532
532
719
2920
2047
2.0E+04
1812
1812
4112
39739
7693
8.1E+04
1.0E+06
1.0E+06
5.9E+06
1.8E+07
8.3E+06
1.4E+07
3.0E+04
3.0E+04
9.0E+04
1.1E+06
1.9E+05
1.4E+06
6.1E+03
6.1E+03
1.2E+04
1.5E+05
2.3E+04
2.3E+05
787
787
1.4E+03
9.4E+03
2.9E+03
3.1E+04
216
216
309
1.5E+03
806
8.1E+03
116
116
146
592
387
4.2E+03
58
58
71
2.9E+02
2.6E+02
2.4E+03
Total Dose
Playset Total Dose
Playset Surf Inges-HandToMouth Dose
Playset Soil Inges-Direct Dose
Playset Surf Derm Dose
Playset Soil Derm Dose
Deck Total Dose
Deck Surf Inges-HandToMouth Dose
Deck Soil Inges-Direct Dose
Deck Surf Derm Dose
Deck Soil Derm Dose
1
1
1
1
1
1
1
1
1
1
1
752
752
752
752
752
752
752
752
752
752
752
393
779
1.4E+03
5.8E+03
2.9E+03
3.0E+04
795
1.3E+03
4.9E+04
2.2E+03
2.0E+05
263
417
651
1.8E+03
1.3E+03
1.6E+04
463
7.4E+02
2.0E+04
1.1E+03
1.1E+05
739
1978
4.6E+03
3.2E+04
8.1E+03
7.2E+04
1905
3.4E+03
2.3E+05
5.2E+03
6.0E+05
70965
2.1E+06
3.7E+06
1.6E+08
5.0E+06
3.2E+08
N/A
N/A
N/A
N/A
N/A
5681
2.6E+04
7.5E+04
1.1E+06
1.3E+05
1.3E+06
2.8E+04
6.7E+04
1.4E+07
9.5E+04
2.2E+07
1902
5.3E+03
1.7E+04
1.3E+05
2.4E+04
2.2E+05
5.6E+03
1.1E+04
9.6E+05
1.7E+04
1.8E+06
354
800
1.5E+03
7.9E+03
2.9E+03
2.8E+04
706
1.2E+03
6.4E+04
2.0E+03
2.0E+05
111
190
301
1.5E+03
712
7.7E+03
225
343
1.1E+04
622
5.3E+04
52
78
121
408
270
3.3E+03
85
1.3E+02
4.1E+03
2.5E+02
2.2E+04
25
45
60
93
81
1625
46
75
1.2E+03
71
9.8E+03
* MOEs calculated by dividing the LOAEL by the ADD reported in Table 16 of the SHEDS-Wood document.
The LOAEL of 0.05 mg/kg/day is used in this assessment.
Table 4. Probabilistic Estimates of Intermediate-Term MOEs for Children Exposed to Arsenic Dislodgeable Residues and Contaminated Soil from Treated Wood Playsets and
Residential Decks in Cold Climate (separated by children with and without decks) [Based on intermediate-term ADDs in Table 17 from the SHEDS-Wood Document.]*
Pathway
Deck
n
mean
std
p50
Total Dose
Playset Total Dose
Playset Surf Inges-HandToMouth Dose
Playset Soil Inges-Direct Dose
Playset Surf Derm Dose
Playset Soil Derm Dose
0
0
0
0
0
0
721
721
721
721
721
721
1.3E+03
1.3E+03
1.5E+03
1.7E+05
1.1E+04
1.9E+06
355
355
420
3.6E+04
2.2E+03
5.4E+05
4.6E+03
4.6E+03
5.9E+03
1.4E+06
3.3E+04
1.2E+07
Total Dose
Playset Total Dose
Playset Surf Inges-HandToMouth Dose
Playset Soil Inges-Direct Dose
Playset Surf Derm Dose
Playset Soil Derm Dose
Deck Total Dose
Deck Surf Inges-HandToMouth Dose
Deck Soil Inges-Direct Dose
Deck Surf Derm Dose
Deck Soil Derm Dose
1
1
1
1
1
1
1
1
1
1
1
742
742
742
742
742
742
742
742
742
742
742
7.2E+02
1.5E+03
1.8E+03
1.3E+05
1.2E+04
1.5E+06
1.4E+03
1.6E+03
6.0E+04
1.0E+04
7.7E+05
357
667
740
3.1E+04
5.8E+03
4.4E+05
467
503
2.5E+04
5.3E+03
4.3E+05
1.6E+03
4.4E+03
5.5E+03
1.3E+06
3.4E+04
8.4E+06
3.5E+03
4.5E+03
2.3E+05
2.6E+04
1.7E+06
min
6.9E+04
* MOEs calculated by dividing the LOAEL by the ADD reported in Table 17 of the SHEDS-Wood document.
The LOAEL of 0.05 mg/kg/day is used in this assessment.
p05
p25
p75
p95
p99
max
8.8E+04
8.8E+04
1.2E+05
1.2E+08
7.7E+05
3.7E+08
1.3E+04
1.3E+04
1.8E+04
8.4E+06
1.1E+05
4.6E+07
1.6E+03
1.6E+03
1.9E+03
3.4E+05
1.3E+04
3.3E+06
415
415
477
4.5E+04
3.4E+03
5.2E+05
128
128
135
1.3E+04
1.3E+03
1.2E+05
16
16
20
1.9E+03
92
3.6E+04
1.3E+04
8.0E+04
1.0E+05
6.6E+07
6.9E+05
2.8E+08
4.1E+04
7.4E+04
8.9E+06
4.8E+05
3.1E+07
3.6E+03
1.4E+04
1.7E+04
6.8E+06
1.2E+05
3.2E+07
9.7E+03
1.4E+04
9.9E+05
7.2E+04
4.7E+06
676
1.5E+03
1.8E+03
2.8E+05
1.1E+04
2.4E+06
1.5E+03
1.8E+03
6.8E+04
9.7E+03
7.2E+05
211
404
479
2.7E+04
3.1E+03
4.0E+05
358
418
1.5E+04
2.7E+03
2.1E+05
84
162
192
9.8E+03
1.1E+03
9.9E+04
161
177
5.3E+03
1.5E+03
8.0E+04
21
39
44
2.0E+03
400
3.4E+04
22
23
2.2E+03
3.7E+02
3.7E+04
Table 5. Probabilistic Estimates of Short-Term MOEs for Children Exposed to Arsenic Dislodgeable Residues and Contaminated Soil from Treated Wood Playsets and Residential
Decks in Warm Climate (separated by children with and without decks)[Based on short-term ADDs in Table 18 from the SHEDS-Wood Document.]*
Pathway
Deck
n
mean
std
p50
min
p05
p25
p75
p95
p99
max
Total Dose
Playset Total Dose
Playset Surf Inges-HandToMouth Dose
Playset Soil Inges-Direct Dose
Playset Surf Derm Dose
Playset Soil Derm Dose
0
0
0
0
0
0
755
755
755
755
755
755
595
595
951
6.0E+03
2.3E+03
3.2E+04
230
230
304
2.0E+03
911
1.6E+04
1667
1667
3361
2.9E+04
7.1E+03
7.7E+04
N/A
N/A
N/A
N/A
N/A
N/A
26449
26449
76029
8.3E+05
156896
1.1E+06
4623
4623
10925
1.2E+05
2.4E+04
2.5E+05
605
605
1126
7.8E+03
2455
3.1E+04
173
173
263
1.2E+03
6.7E+02
8.6E+03
61
61
90
470
192
3.1E+03
12
12
16
109
60
1.4E+03
Total Dose
Playset Total Dose
Playset Surf Inges-Hand To Mouth Dose
Playset Soil Inges-Direct Dose
Playset Surf Derm Dose
Playset Soil Derm Dose
Deck Total Dose
Deck Surf Inges-Hand To Mouth Dose
Deck Soil Inges-Direct Dose
Deck Surf Derm Dose
Deck Soil Derm Dose
1
1
1
1
1
1
1
1
1
1
1
710
710
710
710
710
710
710
710
710
710
710
383
686
1.1E+03
6.4E+03
2.7E+03
2.7E+04
868
1.3E+03
6.5E+04
2.6E+03
2.8E+05
261
404
565
2.0E+03
1.5E+03
1.2E+04
438
643
2.3E+04
1.1E+03
1.5E+05
771
1747
3.4E+03
3.1E+04
8.0E+03
7.6E+04
2380
4.4E+03
3.7E+05
8.4E+03
8.6E+05
61169
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
7520
24985
74934
8.2E+05
1.5E+05
1.2E+06
N/A
N/A
N/A
N/A
N/A
1908
5164
1.3E+04
1.3E+05
2.6E+04
2.2E+05
8816
1.7E+04
2.4E+06
3.3E+04
3.7E+06
333
612
1102
8.1E+03
2.5E+03
2.6E+04
853
1327
1.0E+05
3.0E+03
2.7E+05
107
175
274
1609
663
6.8E+03
198
304
1.3E+04
643
6.9E+04
53
93
118
427
342
2.9E+03
75
138
5.0E+03
254
3.3E+04
32
45
64
134
146
694
50
60
2.1E+03
100
1.4E+04
* MOEs calculated by dividing the LOAEL by the ADD reported in Table 18 of the SHEDS-Wood document.
The LOAEL of 0.05 mg/kg/day is used in this assessment.
Table 6. Probabilistic Estimates of Short-Term MOEs for Children Exposed to Arsenic Dislodgeable Residues and Contaminated Soil from Treated Wood Playsets and Residential Decks in
Cold Climate (separated by children with and without decks)[Based on short-term ADDs in Table 19 from the SHEDS-Wood Document.]*
Pathway
Deck
n
mean
std
p50
min
p05
p25
p75
p95
p99
max
Total Dose
Playset Total Dose
Playset Surf Inges-Hand To Mouth Dose
Playset Soil Inges-Direct Dose
Playset Surf Derm Dose
Playset Soil Derm Dose
0
0
0
0
0
0
742
742
742
742
742
742
1.2E+03
1.2E+03
1.3E+03
1.2E+05
1.0E+04
1.9E+06
482
482
533
2.7E+04
3.7E+03
4.8E+05
3.6E+03
3.6E+03
4.4E+03
1.4E+06
3.4E+04
1.0E+07
N/A
N/A
N/A
N/A
N/A
N/A
5.0E+05
5.0E+05
5.6E+05
8.8E+08
5.3E+06
1.2E+09
1.3E+04
1.3E+04
1.6E+04
6.8E+06
1.0E+05
4.9E+07
1.15E+03
1.15E+03
1.34E+03
2.9E+05
1.1E+04
2.8E+06
304
304
360
3.0E+04
2.7E+03
4.4E+05
108
108
111
5.1E+03
976
1.5E+05
38
38
40
1.7E+03
1.8E+02
2.3E+04
Total Dose
Playset Total Dose
Playset Surf Inges-Hand To Mouth Dose
Playset Soil Inges-Direct Dose
Playset Surf Derm Dose
Playset Soil Derm Dose
Deck Total Dose
Deck Surf Inges-Hand To Mouth Dose
Deck Soil Inges-Direct Dose
Deck Surf Derm Dose
Deck Soil Derm Dose
1
1
1
1
1
1
1
1
1
1
1
720
720
720
720
720
720
720
720
720
720
720
745
1.3E+03
1.4E+03
1.0E+05
1.2E+04
1.8E+06
1.8E+03
2.1E+03
6.5E+04
1.5E+04
9.2E+05
309
454
490
1.9E+04
5.3E+03
6.7E+05
563
621
2.1E+04
5.6E+03
3.7E+05
2023
4455
5454
1.6E+06
3.8E+04
1.0E+07
6845
9294
6.0E+05
5.8E+04
3.7E+06
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
2.43E+04
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
4.78E+03
1.48E+04
1.86E+04
6.6E+06
1.2E+05
4.4E+07
1.69E+05
1.02E+06
1.3E+08
4.1E+06
9.1E+08
739
1.44E+03
1.69E+03
3.2E+05
1.2E+04
2.5E+06
2.19E+03
2.70E+03
1.0E+05
1.7E+04
1.0E+06
230
328
369
2.7E+04
2.9E+03
3.7E+05
488
556
1.3E+04
3.6E+03
1.9E+05
72
118
126
6.8E+03
1.1E+03
1.5E+05
175
218
4.8E+03
1.5E+03
9.0E+04
21
26
28
1.0E+03
431
6.2E+04
30
32
1.4E+03
350
2.1E+04
* MOEs calculated by dividing the LOAEL by the ADD reported in Table 19 of the SHEDS-Wood document.
The LOAEL of 0.05 mg/kg/day is used in this assessment.
Table 7. Probabilistic Estimates of Short-Term MOEs for Children Exposed to Arsenic Dislodgeable Residues and Contaminated Soil from Treated Wood Playsets and Residential
Decks in Warm Climate (children with PICA behavior) [Based on short-term ADD from Table 33 in SHEDS-Wood document]*
Pathway
Deck
n
mean
std
p50
min
p05
p25
p75
p95
p99
max
Playset Total Dose
Playset Surf Inges-HandToMouth Dose
Playset Soil Inges-Direct Dose
Playset Surf Derm Dose
Playset Soil Derm Dose
0
0
0
0
0
288
288
288
288
288
219
1.3E+03
299
2.6E+03
2.5E+04
125
781
135
1.4E+03
1.3E+04
503
3.3E+03
955
6.6E+03
5.7E+04
2.3E+05
8.0E+05
5.7E+05
1.4E+06
4.8E+07
7.9E+03
5.4E+04
1.8E+04
1.5E+05
2.2E+06
1.3E+03
9.7E+03
2.3E+03
2.4E+04
2.3E+05
207
1.4E+03
336
2.4E+03
2.6E+04
65
250
69
624
6.2E+03
23
170
24
266
2.2E+03
14
121
15
144
1.6E+03
Total Dose
Playset Total Dose
Playset Surf Inges-HandToMouth Dose
Playset Soil Inges-Direct Dose
Playset Surf Derm Dose
Playset Soil Derm Dose
Deck Total Dose
Deck Surf Inges-HandToMouth Dose
Deck Soil Inges-Direct Dose
Deck Surf Derm Dose
Deck Soil Derm Dose
1
1
1
1
1
1
1
1
1
1
1
318
318
318
318
318
318
318
318
318
318
318
163
207
1.1E+03
287
2.6E+03
2.6E+04
7.8E+02
1.4E+03
3.7E+03
3.1E+03
2.8E+05
94
102
416
115
1.4E+03
1.7E+04
404
609
1.5E+03
1.2E+03
1.2E+05
339
549
3.7E+03
955
6.5E+03
5.9E+04
2.3E+03
6.1E+03
1.4E+04
1.2E+04
1.0E+06
1.2E+04
3.0E+04
1.4E+06
3.3E+04
9.6E+05
4.4E+06
1.4E+03
3.6E+03
4.9E+04
6.8E+03
1.3E+05
8.0E+05
6.5E+02
1.2E+03
8.9E+03
2.3E+03
1.9E+04
1.6E+05
7.3E+03
2.5E+04
1.1E+05
4.5E+04
6.9E+06
155
193
1.3E+03
3.3E+02
2.7E+03
2.3E+04
834
2.0E+03
3.8E+03
3.8E+03
3.3E+05
49
59
233
66
698
6.0E+03
183
302
787
822
6.2E+04
31
32
93
33
288
3.6E+03
72
116
461
304
2.2E+04
7
8
32
8
157
2.3E+03
52
68
104
90
1.2E+04
* MOEs calculated by dividing the LOAEL by the ADD reported in Table 33 of the SHEDS-Wood document.
The LOAEL of 0.05 mg/kg/day is used in this assessment.
Table 8. Probabilistic Estimates of Cancer Risks for Children Exposed to Arsenic Dislodgeable Residues and Contaminated Soil from Treated Wood Playsets and Residential
Decks in Warm Climate (Dermal Residue Absorption Rate =0.01%)[Based on LADDs in Table 35 from the SHEDS-Wood Document]*
Pathway
Deck
n
mean
std
p50
min
p05
p25
p75
p95
p99
max
Total Dose
Playset Total Dose
Playset Surf Inges-HandToMouth Dose
Playset Soil Inges-Direct Dose
Playset Surf Derm Dose
Playset Soil Derm Dose
0
0
0
0
0
0
731
731
731
731
731
731
1.5E-05
1.5E-05
1.1E-05
2.7E-06
1.8E-08
6.1E-07
3.3E-05
3.3E-05
3.2E-05
5.7E-06
3.8E-08
7.7E-07
7.3E-06
7.3E-06
4.0E-06
9.5E-07
8.4E-09
4.0E-07
1.2E-08
1.2E-08
7.7E-09
9.5E-10
2.6E-11
6.8E-10
1.0E-06
1.0E-06
3.7E-07
5.3E-08
9.6E-10
4.7E-08
3.4E-06
3.4E-06
1.6E-06
3.1E-07
3.4E-09
1.8E-07
1.6E-05
1.6E-05
1.1E-05
2.9E-06
2.1E-08
7.5E-07
4.4E-05
4.4E-05
3.6E-05
1.1E-05
6.0E-08
1.8E-06
1.2E-04
1.2E-04
1.1E-04
2.8E-05
1.4E-07
3.7E-06
7.1E-04
7.1E-04
7.1E-04
8.9E-05
7.5E-07
9.4E-06
Total Dose
Playset Total Dose
Playset Surf Inges-HandToMouth Dose
Playset Soil Inges-Direct Dose
Playset Surf Derm Dose
Playset Soil Derm Dose
Deck Total Dose
Deck Surf Inges-HandToMouth Dose
Deck Soil Inges-Direct Dose
Deck Surf Derm Dose
Deck Soil Derm Dose
1
1
1
1
1
1
1
1
1
1
1
740
740
740
740
740
740
740
740
740
740
740
2.9E-05
1.4E-05
1.1E-05
1.7E-06
1.9E-08
3.7E-07
1.6E-05
1.5E-05
3.3E-07
2.9E-08
7.9E-08
5.0E-05
2.1E-05
2.1E-05
3.3E-06
3.1E-08
4.7E-07
3.3E-05
3.3E-05
1.0E-06
5.9E-08
1.1E-07
1.7E-05
7.6E-06
5.5E-06
5.5E-07
9.9E-09
2.2E-07
6.9E-06
6.4E-06
8.8E-08
1.4E-08
4.2E-08
4.1E-07
6.3E-08
3.8E-08
4.1E-09
5.1E-11
1.7E-09
1.3E-07
5.9E-08
5.3E-11
8.8E-11
1.6E-12
2.3E-06
1.0E-06
4.0E-07
3.6E-08
1.2E-09
2.8E-08
6.9E-07
4.9E-07
2.8E-09
1.2E-09
1.3E-09
7.3E-06
3.3E-06
1.9E-06
2.1E-07
4.3E-09
1.1E-07
2.7E-06
2.3E-06
2.2E-08
5.5E-09
1.5E-08
3.2E-05
1.6E-05
1.3E-05
1.7E-06
2.1E-08
4.5E-07
1.7E-05
1.7E-05
2.6E-07
3.2E-08
9.3E-08
9.8E-05
4.1E-05
3.9E-05
7.8E-06
6.1E-08
1.1E-06
5.6E-05
5.6E-05
1.3E-06
8.7E-08
3.0E-07
2.3E-04
1.2E-04
1.1E-04
1.5E-05
1.6E-07
2.7E-06
1.3E-04
1.2E-04
3.8E-06
1.9E-07
5.6E-07
8.6E-04
2.9E-04
2.9E-04
3.2E-05
3.7E-07
5.2E-06
5.7E-04
5.7E-04
1.6E-05
9.0E-07
9.3E-07
* Cancer Risks calculated by multiplying the slope factor (Q1*) times the LADD reported in the revised Table 35 of the SHEDS-Wood document.
The slope factor (Q1*) of 3.67 (mg/kg/day)-1 is used in this assessment.
Table 9. Probabilistic Estimates of Cancer Risks for Children Exposed to Arsenic Dislodgeable Residues and Contaminated Soil from Treated Wood Playsets and Residential
Decks in Cold Climate (Dermal Residue Absorption Rate =0.01%)[Based on LADDs in the Table 36 from the SHEDS-Wood Document]*
Pathway
Deck
n
mean
std
p50
min
p05
p25
p75
p95
p99
max
Total Dose
Playset Total Dose
Playset Surf Inges-HandToMouth Dose
Playset Soil Inges-Direct Dose
Playset Surf Derm Dose
Playset Soil Derm Dose
0
0
0
0
0
0
761
761
761
761
761
761
1.1E-05
1.1E-05
1.0E-05
1.9E-07
5.3E-09
1.5E-08
2.4E-05
2.4E-05
2.4E-05
4.9E-07
1.1E-08
2.8E-08
4.2E-06
4.2E-06
3.9E-06
4.5E-08
2.3E-09
5.5E-09
4.4E-08
4.4E-08
4.4E-08
1.3E-10
6.0E-11
3.4E-11
5.6E-07
5.6E-07
4.1E-07
1.6E-09
3.4E-10
4.3E-10
1.8E-06
1.8E-06
1.6E-06
1.1E-08
1.0E-09
2.0E-09
1.1E-05
1.1E-05
1.0E-05
1.6E-07
5.6E-09
1.5E-08
3.8E-05
3.8E-05
3.8E-05
7.2E-07
1.8E-08
5.4E-08
9.9E-05
9.9E-05
9.9E-05
2.8E-06
4.3E-08
1.4E-07
4.3E-04
4.3E-04
4.3E-04
6.6E-06
1.9E-07
3.0E-07
Total Dose
Playset Total Dose
Playset Surf Inges-HandToMouth Dose
Playset Soil Inges-Direct Dose
Playset Surf Derm Dose
Playset Soil Derm Dose
Deck Total Dose
Deck Surf Inges-HandToMouth Dose
Deck Soil Inges-Direct Dose
Deck Surf Derm Dose
Deck Soil Derm Dose
1
1
1
1
1
1
1
1
1
1
1
713
713
713
713
713
713
713
713
713
713
713
2.0E-05
9.4E-06
9.3E-06
4.6E-08
4.9E-09
3.6E-09
1.0E-05
1.0E-05
2.9E-07
5.9E-09
2.2E-08
3.1E-05
1.6E-05
1.6E-05
1.4E-07
7.6E-09
7.8E-09
1.7E-05
1.7E-05
6.9E-07
9.7E-09
3.1E-08
9.8E-06
4.3E-06
4.2E-06
9.7E-09
2.4E-09
1.2E-09
5.1E-06
4.8E-06
8.1E-08
3.0E-09
1.2E-08
1.7E-07
2.9E-08
2.9E-08
1.5E-12
1.8E-11
9.0E-12
3.6E-08
2.0E-08
2.3E-10
2.8E-11
1.7E-11
1.3E-06
4.6E-07
4.2E-07
3.6E-10
3.2E-10
1.0E-10
5.9E-07
3.7E-07
3.3E-09
3.5E-10
8.6E-10
4.5E-06
1.9E-06
1.9E-06
2.6E-09
1.2E-09
4.3E-10
2.1E-06
1.8E-06
2.4E-08
1.4E-09
4.5E-09
2.0E-05
9.8E-06
9.7E-06
3.6E-08
5.8E-09
3.5E-09
1.1E-05
1.0E-05
2.4E-07
6.9E-09
2.6E-08
7.7E-05
3.5E-05
3.5E-05
2.0E-07
1.6E-08
1.5E-08
3.7E-05
3.7E-05
1.2E-06
1.9E-08
7.9E-08
1.6E-04
9.1E-05
9.1E-05
5.8E-07
3.4E-08
3.3E-08
9.0E-05
8.8E-05
3.4E-06
4.7E-08
1.6E-07
3.0E-04
1.6E-04
1.6E-04
2.7E-06
8.1E-08
1.1E-07
1.6E-04
1.6E-04
9.9E-06
1.3E-07
3.8E-07
* Cancer Risks calculated by multiplying the slope factor (Q1*) times the LADD reported in the revised Table 39 of the SHEDS-Wood document.
The slope factor (Q1*) of 3.67 (mg/kg/day)-1 is used in this assessment.
Table 10. Probabilistic Cancer Risk Estimates of Children Exposed to Arsenic Dislodgeable Residues and Contaminated Soil from Treated Wood Playsets and Residential Decks in
Warm Climate (reducing deck and playset residue concentration by 90%) [Based on LADDs in Table 37 from the SHEDS-Wood Document.]*
Pathway
Deck
n
mean
std
p50
min
p05
p25
p75
p95
p99
max
Total Dose
Playset Total Dose
Playset Surf Inges-Hand To Mouth Dose
Playset Soil Inges-Direct Dose
Playset Surf Derm Dose
Playset Surf Derm Dose
0
0
0
0
0
0
700
700
700
700
700
700
3.3E-06
3.3E-06
8.2E-07
1.8E-06
4.3E-07
2.7E-07
4.0E-06
4.0E-06
1.4E-06
3.3E-06
6.5E-07
3.1E-07
2.0E-06
2.0E-06
3.5E-07
6.3E-07
2.0E-07
1.8E-07
1.2E-08
1.2E-08
7.2E-10
1.2E-09
1.8E-09
3.1E-09
2.6E-07
2.6E-07
1.8E-08
3.5E-08
1.6E-08
3.2E-08
9.4E-07
9.4E-07
1.2E-07
2.0E-07
7.6E-08
9.4E-08
3.9E-06
3.9E-06
9.1E-07
1.9E-06
5.1E-07
3.2E-07
1.1E-05
1.1E-05
3.0E-06
7.0E-06
1.6E-06
7.8E-07
2.1E-05
2.1E-05
7.1E-06
1.7E-05
3.5E-06
1.9E-06
4.2E-05
4.2E-05
1.7E-05
4.2E-05
5.8E-06
2.6E-06
Total Dose
Playset Total Dose
Playset Surf Inges-Hand To Mouth Dose
Playset Soil Inges-Direct Dose
Playset Surf Derm Dose
Playset Soil Derm Dose
Deck Total Dose
Deck Surf Inges-Hand To Mouth Dose
Deck Soil Inges-Direct Dose
Deck Surf Derm Dose
Deck Soil Derm Dose
1
1
1
1
1
1
1
1
1
1
1
759
759
759
759
759
759
759
759
759
759
759
6.6E-06
4.0E-06
8.8E-07
2.4E-06
4.3E-07
3.1E-07
2.5E-06
1.4E-06
2.9E-07
7.5E-07
6.0E-08
8.3E-06
5.1E-06
1.9E-06
4.3E-06
7.2E-07
3.7E-07
4.9E-06
3.7E-06
5.4E-07
1.3E-06
6.9E-08
3.9E-06
2.3E-06
2.6E-07
8.8E-07
1.7E-07
2.0E-07
1.2E-06
4.7E-07
9.0E-08
3.2E-07
3.5E-08
7.1E-08
2.5E-09
2.3E-10
1.2E-10
1.1E-10
9.5E-10
7.0E-09
4.0E-10
7.9E-12
3.2E-10
2.9E-11
7.1E-07
3.1E-07
1.3E-08
5.3E-08
1.2E-08
2.9E-08
1.6E-07
2.7E-08
3.2E-09
2.0E-08
2.1E-09
1.9E-06
1.0E-06
7.8E-08
3.1E-07
6.1E-08
1.1E-07
5.6E-07
1.8E-07
2.5E-08
1.3E-07
1.3E-08
8.6E-06
4.9E-06
8.2E-07
2.5E-06
4.6E-07
3.8E-07
2.8E-06
1.4E-06
2.8E-07
8.0E-07
8.0E-08
2.1E-05
1.4E-05
3.7E-06
9.6E-06
1.6E-06
9.8E-07
8.4E-06
5.6E-06
1.4E-06
2.8E-06
2.1E-07
3.7E-05
2.7E-05
9.1E-06
2.5E-05
3.7E-06
1.8E-06
2.0E-05
1.4E-05
2.9E-06
5.8E-06
3.4E-07
1.2E-04
3.9E-05
2.1E-05
3.9E-05
6.2E-06
3.9E-06
9.4E-05
7.6E-05
4.4E-06
1.8E-05
4.8E-07
* Cancer Risks calculated by multiplying the slope factor (Q1*) times the LADD reported in the revised Table 37 of the SHEDS-Wood document.
The slope factor (Q1*) of 3.67 (mg/kg/day)-1 is used in this assessment.
Table 11. Probabilistic Estimates of Cancer Risk for Children Exposed to Arsenic Dislodgeable Residues and Contaminated Soil from Treated Wood Playsets and Residential Decks in
Warm Climate (reducing deck and playset residue concentration by 99.5%)[Based on the Table 38 from the SHEDS-Wood Document.]*
Pathway
Deck
n
mean
std
p50
min
p05
p25
p75
p95
p99
max
Total Dose
Playset Total Dose
Playset Surf Inges-HandToMouth Dose
Playset Soil Inges-Direct Dose
Playset Surf Derm Dose
Playset Soil Derm Dose
0
0
0
0
0
0
743
743
743
743
743
743
2.0E-06
2.0E-06
2.1E-08
1.9E-06
1.2E-08
6.0E-08
3.5E-06
3.5E-06
8.2E-08
3.4E-06
3.3E-08
1.0E-07
8.1E-07
8.1E-07
2.5E-09
6.9E-07
2.3E-09
3.3E-08
3.6E-09
3.6E-09
2.1E-12
1.0E-09
4.7E-12
1.2E-09
8.6E-08
8.6E-08
7.7E-11
4.5E-08
8.2E-11
5.2E-09
3.1E-07
3.1E-07
5.5E-10
2.3E-07
5.8E-10
1.5E-08
2.3E-06
2.3E-06
9.8E-09
2.0E-06
8.0E-09
6.8E-08
8.2E-06
8.2E-06
8.0E-08
8.1E-06
5.4E-08
1.9E-07
1.7E-05
1.7E-05
2.8E-07
1.7E-05
1.5E-07
4.5E-07
3.3E-05
3.3E-05
1.6E-06
3.3E-05
5.2E-07
2.0E-06
Total Dose
Playset Total Dose
Playset Surf Inges-HandToMouth Dose
Playset Soil Inges-Direct Dose
Playset Surf Derm Dose
Playset Soil Derm Dose
Deck Total Dose
Deck Surf Inges-HandToMouth Dose
Deck Soil Inges-Direct Dose
Deck Surf Derm Dose
Deck Soil Derm Dose
1
1
1
1
1
1
1
1
1
1
1
721
721
721
721
721
721
721
721
721
721
721
2.9E-06
2.5E-06
1.2E-08
2.5E-06
7.2E-09
5.5E-08
4.0E-07
4.7E-08
3.0E-07
2.8E-08
2.0E-08
4.6E-06
4.3E-06
4.1E-08
4.3E-06
2.0E-08
7.3E-08
7.7E-07
1.6E-07
7.2E-07
7.8E-08
2.4E-08
1.3E-06
1.1E-06
1.9E-09
1.0E-06
1.6E-09
3.1E-08
1.8E-07
1.1E-08
8.8E-08
8.1E-09
1.3E-08
1.0E-08
2.7E-09
2.8E-12
1.5E-09
3.7E-12
6.2E-10
1.8E-09
4.7E-12
3.9E-11
8.9E-12
8.8E-11
1.6E-07
8.9E-08
3.8E-11
5.0E-08
4.9E-11
4.3E-09
1.8E-08
2.3E-10
2.4E-09
3.0E-10
1.4E-09
5.3E-07
3.7E-07
5.3E-10
2.9E-07
4.7E-10
1.4E-08
7.3E-08
2.5E-09
2.3E-08
2.1E-09
6.0E-09
3.4E-06
2.9E-06
8.1E-09
2.8E-06
5.6E-09
6.5E-08
4.3E-07
3.8E-08
3.0E-07
2.7E-08
2.6E-08
1.1E-05
1.0E-05
4.4E-08
9.9E-06
2.6E-08
1.9E-07
1.4E-06
1.8E-07
1.2E-06
1.0E-07
6.7E-08
2.9E-05
2.2E-05
2.1E-07
2.2E-05
1.0E-07
3.6E-07
3.3E-06
5.6E-07
2.8E-06
2.9E-07
1.3E-07
3.8E-05
3.7E-05
6.1E-07
3.7E-05
2.5E-07
7.3E-07
1.2E-05
2.5E-06
1.1E-05
1.5E-06
1.9E-07
* Cancer Risks calculated by multiplying the slope factor (Q1*) times the LADD reported in the revised Table 38 of the SHEDS-Wood document.
The slope factor (Q1*) of 3.67 (mg/kg/day)-1 is used in this assessment.
Table 12. Probabilistic Estimates of Cancer Risks for Children Exposed to Arsenic Dislodgeable Residues and Contaminated Soil from Treated Wood Playsets and Residential Decks
in Warm Climate (reducing exposure washing hands after playing on deck or playset) [Based on LADDs in the Table 39 from the SHEDS-Wood Document.]*
Pathway
Deck
n
mean
std
p50
min
p05
p25
p75
p95
p99
max
Total Dose
Playset Total Dose
Playset Surf Inges-HandToMouth Dose
Playset Soil Inges-Direct Dose
Playset Surf Derm Dose
Playset Soil Derm Dose
0
0
0
0
0
0
747
747
747
747
747
747
1.3E-05
1.3E-05
6.0E-06
2.1E-06
5.0E-06
3.9E-07
1.6E-05
1.6E-05
9.5E-06
4.5E-06
6.7E-06
5.4E-07
7.5E-06
7.5E-06
2.7E-06
6.7E-07
2.7E-06
2.4E-07
2.6E-08
2.6E-08
9.6E-09
1.3E-09
4.3E-09
4.0E-09
1.0E-06
1.0E-06
1.9E-07
3.7E-08
2.5E-07
2.4E-08
3.6E-06
3.6E-06
9.4E-07
2.0E-07
1.2E-06
1.1E-07
1.7E-05
1.7E-05
7.1E-06
2.2E-06
6.3E-06
4.6E-07
4.6E-05
4.6E-05
2.1E-05
8.1E-06
1.9E-05
1.3E-06
7.3E-05
7.3E-05
3.9E-05
2.4E-05
3.3E-05
2.9E-06
1.7E-04
1.7E-04
1.1E-04
5.2E-05
5.5E-05
6.4E-06
Total Dose
Playset Total Dose
Playset Surf Inges-Hand To Mouth Dose
Playset Soil Inges-Direct Dose
Playset Surf Derm Dose
Playset Soil Derm Dose
Deck Total Dose
Deck Surf Inges-Hand To Mouth Dose
Deck Soil Inges-Direct Dose
Deck Surf Derm Dose
Deck Soil Derm Dose
1
1
1
1
1
1
1
1
1
1
1
704
704
704
704
704
704
704
704
704
704
704
3.1E-05
1.4E-05
5.9E-06
2.3E-06
5.0E-06
5.0E-07
1.7E-05
8.5E-06
3.1E-07
8.2E-06
7.5E-08
4.6E-05
2.0E-05
1.2E-05
4.0E-06
8.5E-06
6.0E-07
3.2E-05
1.6E-05
6.9E-07
1.8E-05
1.2E-07
1.8E-05
8.2E-06
2.7E-06
8.4E-07
2.6E-06
3.1E-07
7.5E-06
3.3E-06
7.9E-08
3.4E-06
3.6E-08
4.7E-07
2.3E-07
1.1E-08
1.3E-08
4.0E-08
3.8E-09
5.7E-09
3.1E-09
1.9E-11
2.4E-09
3.3E-11
3.3E-06
1.2E-06
2.4E-07
6.1E-08
2.6E-07
4.7E-08
7.4E-07
2.5E-07
2.3E-09
2.8E-07
1.7E-09
9.1E-06
4.1E-06
1.1E-06
3.0E-07
1.1E-06
1.4E-07
3.3E-06
1.3E-06
2.1E-08
1.4E-06
1.2E-08
3.5E-05
1.6E-05
5.8E-06
2.6E-06
5.8E-06
6.3E-07
1.8E-05
8.8E-06
2.8E-07
8.4E-06
8.9E-08
1.0E-04
4.5E-05
2.0E-05
8.7E-06
1.5E-05
1.7E-06
5.6E-05
2.9E-05
1.4E-06
2.9E-05
2.9E-07
2.6E-04
1.0E-04
6.1E-05
2.0E-05
3.8E-05
2.8E-06
1.7E-04
9.1E-05
3.6E-06
6.5E-05
4.9E-07
4.5E-04
2.0E-04
1.5E-04
4.8E-05
1.0E-04
6.1E-06
3.8E-04
1.7E-04
7.3E-06
2.2E-04
1.3E-06
* Cancer Risks calculated by multiplying the slope factor (Q1*) times the LADD reported in the revised Table 39 of the SHEDS-Wood document.
The slope factor (Q1*) of 3.67 (mg/kg/day)-1 is used in this assessment.
Table 13. Probabilistic Estimates of Cancer Risks for Children Exposed to Arsenic Dislodgeable Residues and Contaminated Soil from Treated Wood Playsets and Residential Decks
in Warm Climate (simulating 90% residue reduction and hand washing to reduce exposure) [Based on LADDs in the revised Table 40 from the SHEDS-Wood Document.]*
Pathway
Deck
n
mean
std
p50
min
p05
p25
p75
p95
p99
max
Total Dose
Playset Total Dose
Playset Surf Inges-HandToMouth Dose
Playset Soil Inges-Direct Dose
Playset Surf Derm Dose
Playset Soil Derm Dose
0
0
0
0
0
0
713
713
713
713
713
713
3.6E-06
3.6E-06
5.9E-07
2.1E-06
5.6E-07
3.0E-07
5.3E-06
5.3E-06
1.2E-06
4.4E-06
1.6E-06
4.1E-07
1.9E-06
1.9E-06
2.1E-07
7.8E-07
2.2E-07
1.7E-07
1.6E-08
1.6E-08
6.9E-10
1.2E-09
2.2E-09
2.4E-09
2.7E-07
2.7E-07
1.1E-08
4.5E-08
1.2E-08
2.8E-08
9.1E-07
9.1E-07
6.9E-08
2.3E-07
8.5E-08
8.4E-08
4.5E-06
4.5E-06
5.9E-07
2.1E-06
5.7E-07
3.5E-07
1.2E-05
1.2E-05
2.5E-06
9.1E-06
1.7E-06
1.0E-06
2.3E-05
2.3E-05
6.5E-06
1.7E-05
4.8E-06
2.0E-06
6.8E-05
6.8E-05
1.0E-05
6.5E-05
3.7E-05
4.6E-06
Total Dose
Playset Total Dose
Playset Surf Inges-HandToMouth Dose
Playset Soil Inges-Direct Dose
Playset Surf Derm Dose
Playset Soil Derm Dose
Deck Total Dose
Deck Surf Inges-HandToMouth Dose
Deck Soil Inges-Direct Dose
Deck Surf Derm Dose
Deck Soil Derm Dose
1
1
1
1
1
1
1
1
1
1
1
756
756
756
756
756
756
756
756
756
756
756
5.8E-06
3.6E-06
6.1E-07
2.2E-06
4.5E-07
3.1E-07
2.2E-06
1.1E-06
2.8E-07
8.3E-07
6.0E-08
9.2E-06
4.3E-06
1.5E-06
3.5E-06
8.0E-07
3.7E-07
6.5E-06
4.3E-06
5.9E-07
2.3E-06
8.9E-08
3.3E-06
2.0E-06
1.7E-07
8.2E-07
1.9E-07
2.0E-07
9.9E-07
2.9E-07
7.5E-08
3.2E-07
3.3E-08
1.4E-07
3.8E-09
2.6E-10
4.9E-10
1.0E-09
1.3E-09
1.8E-09
4.5E-10
7.2E-11
9.8E-10
1.3E-11
6.5E-07
3.0E-07
8.9E-09
5.4E-08
1.4E-08
3.5E-08
1.1E-07
1.7E-08
2.0E-09
2.4E-08
1.9E-09
1.8E-06
9.7E-07
5.2E-08
3.1E-07
6.6E-08
9.6E-08
4.6E-07
1.0E-07
2.2E-08
1.2E-07
1.1E-08
6.8E-06
4.5E-06
5.2E-07
2.7E-06
4.5E-07
3.8E-07
2.2E-06
8.8E-07
2.7E-07
8.1E-07
7.5E-08
1.9E-05
1.4E-05
2.4E-06
9.2E-06
1.8E-06
9.6E-07
7.7E-06
4.1E-06
1.4E-06
3.4E-06
2.0E-07
3.1E-05
2.1E-05
7.7E-06
1.7E-05
4.7E-06
2.0E-06
1.7E-05
1.1E-05
2.5E-06
7.8E-06
3.9E-07
1.9E-04
3.2E-05
2.0E-05
2.8E-05
7.6E-06
3.0E-06
1.6E-04
1.1E-04
8.4E-06
4.9E-05
1.2E-06
* Cancer Risks calculated by multiplying the slope factor (Q1*) times the LADD reported in the revised Table 40 of the SHEDS-Wood document.
The slope factor (Q1*) of 3.67 (mg/kg/day)-1 is used in this assessment.
Table 14. Probabilistic Estimates of Cancer Risks for Children Exposed to Arsenic Dislodgeable Residues and Contaminated Soil from Treated Wood Playsets and Residential
Decks in Warm Climate (simulating 99.5% residue reduction and hand washing to reduce exposure[Based on LADDs in the revised Table 41 from the SHEDS-Wood Document.]*
Pathway
Deck
n
mean
std
p50
min
p05
p25
p75
p95
p99
max
Total Dose
Playset Total Dose
Playset Surf Inges-HandToMouth Dose
Playset Soil Inges-Direct Dose
Playset Surf Derm Dose
Playset Soil Derm Dose
0
0
0
0
0
0
729
729
729
729
729
729
2.1E-06
2.1E-06
9.7E-09
2.0E-06
9.6E-09
5.9E-08
3.5E-06
3.5E-06
2.8E-08
3.5E-06
2.2E-08
7.7E-08
7.5E-07
7.5E-07
1.9E-09
6.7E-07
2.7E-09
3.4E-08
1.3E-08
1.3E-08
3.0E-12
3.2E-09
4.9E-12
6.6E-10
7.2E-08
7.2E-08
6.3E-11
3.6E-08
1.1E-10
5.1E-09
2.6E-07
2.6E-07
4.9E-10
2.0E-07
7.3E-10
1.5E-08
2.1E-06
2.1E-06
7.7E-09
2.0E-06
8.2E-09
7.2E-08
9.3E-06
9.3E-06
4.3E-08
9.2E-06
4.0E-08
1.9E-07
1.7E-05
1.7E-05
1.1E-07
1.7E-05
1.2E-07
3.7E-07
3.0E-05
3.0E-05
3.7E-07
3.0E-05
2.5E-07
7.7E-07
Total Dose
Playset Total Dose
Playset Surf Inges-HandToMouth Dose
Playset Soil Inges-Direct Dose
Playset Surf Derm Dose
Playset Soil Derm Dose
Deck Total Dose
Deck Surf Inges-Hand To Mouth Dose
Deck Soil Inges-Direct Dose
Deck Surf Derm Dose
Deck Soil Derm Dose
1
1
1
1
1
1
1
1
1
1
1
738
738
738
738
738
738
738
738
738
738
738
3.4E-06
3.0E-06
9.0E-09
2.9E-06
7.8E-09
5.4E-08
4.1E-07
3.2E-08
3.3E-07
2.8E-08
2.0E-08
6.7E-06
6.4E-06
3.4E-08
6.4E-06
2.7E-08
7.4E-08
6.7E-07
9.9E-08
6.5E-07
6.9E-08
3.1E-08
1.3E-06
1.0E-06
1.0E-09
8.8E-07
1.5E-09
3.1E-08
1.7E-07
6.1E-09
8.8E-08
7.9E-09
1.2E-08
4.0E-08
5.5E-09
3.2E-12
4.2E-09
4.7E-12
7.2E-10
1.1E-09
7.6E-12
9.4E-11
2.3E-11
4.5E-12
1.6E-07
1.1E-07
2.8E-11
7.0E-08
5.0E-11
4.3E-09
1.9E-08
1.4E-10
2.2E-09
2.4E-10
1.3E-09
5.3E-07
3.8E-07
2.5E-10
3.2E-07
3.6E-10
1.4E-08
6.6E-08
1.6E-09
2.2E-08
2.0E-09
5.4E-09
3.4E-06
2.8E-06
4.2E-09
2.6E-06
5.7E-09
6.4E-08
4.8E-07
2.3E-08
3.6E-07
2.5E-08
2.4E-08
1.2E-05
1.1E-05
3.4E-08
1.0E-05
2.7E-08
1.7E-07
1.5E-06
1.4E-07
1.3E-06
1.1E-07
6.5E-08
4.2E-05
4.1E-05
1.7E-07
4.1E-05
1.1E-07
3.5E-07
3.6E-06
3.7E-07
3.5E-06
2.8E-07
1.1E-07
6.8E-05
6.4E-05
4.8E-07
6.4E-05
3.9E-07
8.2E-07
5.5E-06
1.4E-06
5.5E-06
7.7E-07
6.0E-07
* Cancer Risks calculated by multiplying the slope factor (Q1*) times the LADD reported in the revised Table 41 of the SHEDS-Wood-Wood document.
The slope factor (Q1*) of 3.67 (mg/kg/day)-1 is used in this assessment.
Appendix C
Comparison of Total Risks to Risk Reduction Impacts
Figure C-1 Arsenic Cancer Risk at the 95% Percentile (Warm Climate)
2.E-04
1.E-04
Without Decks
1.E-04
With Decks
1.E-04
1.E-04
Cancer Risk
1.E-04
9.E-05
8.E-05
7.E-05
6.E-05
5.E-05
4.E-05
3.E-05
2.E-05
1.E-05
0.E+00
Baseline
Reduction by 90%
Reduction by
99.5%
Hand Washing
Exposure Scenario
Hand Washing
and 90%
Reduction
Hand Washing
and 99.5%
Reduction
Figure C-2 Arsenic Cancer Risk at the 50% Percentile (Warm Climate)
2.50E-05
Without Decks
With Decks
Cancer Risk
2.00E-05
1.50E-05
1.00E-05
5.00E-06
0.00E+00
Baseline
Reduction by 90%
Reduction by
99.5%
Hand Washing
Exposure Scenario
Hand Washing
and 90%
Reduction
Hand Washing
and 99.5%
Reduction
Figure C-3 Arsenic Cancer Risk for the Mean Population (Warm Climate)
5.00E-05
Without Decks
4.50E-05
With Decks
4.00E-05
Cancer Risk
3.50E-05
3.00E-05
2.50E-05
2.00E-05
1.50E-05
1.00E-05
5.00E-06
0.00E+00
Baseline
Reduction by 90%
Reduction by
99.5%
Hand Washing
Mitigation
Hand Washing
and 90%
Reduction
Hand Washing
and 99.5%
Reduction
Figure C-4 Arsenic Cancer Risk for the 95% Population (Cold Climate)
1.00E-04
Without Decks
9.00E-05
With Decks
8.00E-05
Cancer Risk
7.00E-05
6.00E-05
5.00E-05
4.00E-05
3.00E-05
2.00E-05
SHEDs-Wood was not evaluated for
reduction by sealants and hand washing for
cold climates
1.00E-05
0.00E+00
Baseline
Reduction by 90%
Reduction by
99.5%
Hand Washing
Mitigation
Hand Washing
and 90%
Reduction
Hand Washing
and 99.5%
Reduction
Figure C-5 Arsenic Cancer Risk for the 50% Population (Cold Climate)
1.20E-05
1.00E-05
Without Decks
Cancer Risk
8.00E-06
With Decks
6.00E-06
4.00E-06
SHEDs-Wood was not evaluated for
reduction by sealants and hand washing for
cold climates
2.00E-06
0.00E+00
Baseline
Reduction by 90%
Reduction by
99.5%
Hand Washing
Mitigation
Hand Washing
and 90%
Reduction
Hand Washing
and 99.5%
Reduction
Figure C-6 Arsenic Cancer Risk for the Mean Population (Cold Climate)
2.50E-05
Without Decks
With Decks
Cancer Risk
2.00E-05
1.50E-05
1.00E-05
5.00E-06
SHEDs-Wood was not evaluated for
reduction by sealants and hand washing for
cold climates
0.00E+00
Baseline
Reduction by 90%
Reduction by
99.5%
Hand Washing
Mitigation
Hand Washing
and 90%
Reduction
Hand Washing
and 99.5%
Reduction
Figure C-7.
Cancer Risk from Lifetime-Term LADD for Children Exposed to Arsenic
Dislodgeable Residues and Contaminated Soil from Treated Wood
Playsets and Residential Decks in Warm Climate
(Simulating 90% Residue Reduction and Hand Washing to Reduce Exposure)
Scatterplot (E12 (table 40).sta)
1.0
Without Decks
99% = 2.3x10 -5
95% = 1.2x10 -5
50% = 1.9x10 -6
mean = 3.6x10-6
With Decks
99% = 3.1x10 -5
95% = 1.9x10 -5
50% = 3.3x10 -6
mean = 5.8x10-6
0.8
0.7
0.6
0.5
0.4
0.3
Without Decks
With Decks
0.2
hmdeck=0
hmdeck=1
1.0e-3
1.0e-4
1.0e-5
1.0e-6
0.0
1.0e-7
0.1
1.0e-8
Cumulative Probability Density
0.9
Cancer Risk
Histogram (E12 (table 40).sta)
y = 713 * 0.000001 * lognorm (x, -13.1736, 1.17288)
100%
80%
70%
70%
30%
Cancer Risk (Truncated at 1e-5)
(N for Risk > 1e-5 = 120)
1e-5
9e-6
0
1e-5
9e-6
8e-6
7e-6
6e-6
5e-6
4e-6
3e-6
2e-6
1e-6
0%
0
10%
0%
8e-6
20%
10%
7e-6
20%
40%
6e-6
30%
50%
4e-6
40%
60%
3e-6
50%
2e-6
60%
1e-6
Probability Density
80%
Cancer Risk (Truncated at 1e-5)
(N for Risk > 1e-5 = 55)
With Decks
90%
5e-6
Without Decks
90%
Probability Density
Histogram (E12 (table 40).sta)
y = 756 * 0.000001 * lognorm (x, -12.572, 1.013577)
100%
Figure C-8.
Cancer Risk from Lifetime-Term LADD for Children Exposed to Arsenic
Dislodgeable Residues and Contaminated Soil from Treated Wood
Playsets and Residential Decks in Warm Climate
(Simulating 99.5% Residue Reduction and Hand Washing to Reduce Exposure)
Scatterplot (E13 (table 41).sta)
1.0
Without Decks
99% = 1.7x10 -5
95% = 9.3x10 -6
50% = 7.5x10 -7
mean = 2.1x10-6
With Decks
99% = 4.2x10 -5
95% = 1.2x10 -5
50% = 1.3x10 -6
mean = 3.4x10-6
0.8
0.7
0.6
0.5
0.4
0.3
Without Decks
With Decks
0.2
hmdeck=0
hmdeck=1
1.0e-4
1.0e-5
1.0e-6
0.0
1.0e-7
0.1
1.0e-8
Cumulative Probability Density
0.9
Cancer Risk
80%
70%
70%
30%
Cancer Risk (Truncated at 1e-5)
(N for Risk > 1e-5 = 32)
0
1e-5
9e-6
8e-6
7e-6
6e-6
5e-6
4e-6
3e-6
0%
2e-6
10%
0%
1e-6
10%
Cancer Risk (Truncated at 1e-5)
(N for Risk > 1e-5 = 50)
1e-5
20%
9e-6
20%
40%
8e-6
30%
50%
4e-6
40%
3e-6
50%
60%
2e-6
60%
1e-6
Probability Density
80%
0
Probability Density
With Decks
90%
7e-6
Without Decks
90%
6e-6
100%
Histogram (E13 (table 41).sta)
y = 738 * 0.000001 * lognorm (x, -13.52167, 1.33602)
100%
5e-6
Histogram (E13 (table 41).sta)
y = 729 * 0.000001 * lognorm (x, -14.09607, 1.485913)
Table C-1. Probabilistic cancer risk distributions and management goals for children exposed to arsenic
dislodgeable residues and contaminated soil from treated wood playsets and residential decks in warm
climate (reducing exposure by washing hands and reducing deck and playset residue concentration by
90%) (Based on LADDs in Table 40 from the SHEDS-Wood document)
Without Decks
Percentile of
Exposure
maximum
99
95
90
50
10
5
1
minimum
>99.9
92.3
28.1
Lifetime Average Daily Dose
(LADD) ug/kg/day
1.9E-05
6.2E-06
3.2E-06
2.2E-06
5.2E-07
1.2E-07
7.3E-08
2.4E-08
4.4E-09
1.9E-05
2.7E-06
2.7E-07
Cancer Risk
With Decks
Percentile of
Exposure
maximum
99
95
90
50
10
5
1
minimum
99.9
84.1
9.7
Lifetime Average Daily Dose
(LADD) ug/kg/day
5.2E-05
8.4E-06
5.2E-06
3.6E-06
8.9E-07
2.8E-07
1.8E-07
9.5E-08
3.8E-08
1.2E-05
2.7E-06
2.7E-07
Cancer Risk
X = Meets Management Goal
6.8E-05
2.3E-05
1.2E-05
8.2E-06
1.9E-06
4.4E-07
2.7E-07
9.0E-08
1.6E-08
1.0E-04
1.0E-05
1.0E-06
1.9E-04
3.1E-05
1.9E-05
1.3E-05
3.3E-06
1.0E-06
6.5E-07
3.5E-07
1.4E-07
1.0E-04
1.0E-05
1.0E-06
Proposed Management Goals
A = 1.0e-6 B = 1.0e-5 C = 1.0e-4
X
X
X
X
X
X
Proposed Management Goals
A = 1.0e-6 B = 1.0e-5 C = 1.0e-4
X
X
X
X
X
X
Table C-2. Probabilistic cancer risk distributions and management goals for children exposed to
arsenic dislodgeable residues and contaminated soil from treated wood playsets and residential decks
in warm climate (reducing exposure by washing hands and reducing deck and playset residue
concentration by 99.5%) (Based on LADDs in Table 41 from the SHEDS-Wood document)
Without Decks
Percentile of
Exposure
maximum
99
95
90
50
10
5
1
minimum
>99.9
95.6
57.5
Lifetime Average Daily Dose
(LADD) ug/kg/day
8.1E-06
4.7E-06
2.5E-06
1.5E-06
2.0E-07
2.9E-08
2.0E-08
8.0E-09
3.6E-09
8.1E-06
2.6E-06
2.7E-07
Cancer Risk
With Decks
Percentile of
Exposure
maximum
99
95
90
50
10
5
1
minimum
>99.9
93.2
43.6
Lifetime Average Daily Dose
(LADD) ug/kg/day
1.9E-05
1.1E-05
3.2E-06
2.1E-06
3.4E-07
7.1E-08
4.4E-08
2.0E-08
1.1E-08
1.9E-05
2.7E-06
2.7E-07
Cancer Risk
X = Meets Management Goal
3.0E-05
1.7E-05
9.3E-06
5.6E-06
7.5E-07
1.1E-07
7.2E-08
2.9E-08
1.3E-08
1.0E-04
1.0E-05
1.0E-06
6.8E-05
4.2E-05
1.2E-05
7.7E-06
1.3E-06
2.6E-07
1.6E-07
7.3E-08
4.0E-08
1.0E-04
1.0E-05
1.0E-06
Proposed Management Goals
A = 1.0e-6 B = 1.0e-5 C = 1.0e-4
X
X
X
X
X
X
Proposed Management Goals
A = 1.0e-6 B = 1.0e-5 C = 1.0e-4
X
X
X
X
X
X
Appendix D
Comparison of Residue and Soil Risks
Figure D-1 Comparison of Total Arsenic Risks from Playsets and Decks for Warm Climate
Baseline
100
90
Soil risk - playset only
Soil risk - decks & playsets
80
Cumulative Probability Density
Residue risk -playset only
70
Residue risk - decks & playsets
60
50
40
30
20
10
0
1.0E-09
1.0E-08
1.0E-07
1.0E-06
Carcinogenic Risk
1.0E-05
1.0E-04
1.0E-03
Figure D-2 Comparison of Total Arsenic Risks from Decks & Playsets for Warm Climate
90% Reduction and Hand Washing
100
90
Residue risk -playset only
Soil risk - playset only
Cumulative Probability Density
80
70
Residue risk - decks & playsets
Soil risk - decks & playsets
60
50
40
30
20
10
0
1.0E-09
1.0E-08
1.0E-07
1.0E-06
Carcinogenic Risk
1.0E-05
1.0E-04
Figure D-3 Comparison of Residue & Soil Total Arsenic Risks for Warm Climate
Dermal Residue Absorption Rate =0.01%
100
90
Soil risk - decks & playsets
Soil risk - playset only
80
Cumulative Probability Density
Residue risk -playset only
70
Residue risk - decks & playsets
60
50
40
30
20
10
0
1.0E-09
1.0E-08
1.0E-07
1.0E-06
Carcinogenic Risk
1.0E-05
1.0E-04
1.0E-03
Figure D-4 Comparison of Total Arsenic Risks from Decks and Playsets for Warm Climate
90% Reduction
100
90
Residue risk -playset only
80
Cumulative Probability Density
Soil risk - playset only
70
Residue risk - decks & playsets
60
Soil risk - decks & playsets
50
40
30
20
10
0
1.0E-09
1.0E-08
1.0E-07
1.0E-06
Carcinogenic Risk
1.0E-05
1.0E-04
Figure D-5 Comparison of Residue & Soil Total Arsenic Risks for Warm Climate
99.5% Reduction + Hand Wash
100
90
Residue risk -playset only
Soil risk - playset only
80
Cumulative Probability Density
Residue risk - decks & playsets
70
Soil risk - decks & playsets
60
50
40
30
20
10
0
1.0E-12
1.0E-11
1.0E-10
1.0E-09
1.0E-08
Carcinogenic Risk
1.0E-07
1.0E-06
1.0E-05
1.0E-04
Figure D-6 Comparison of Residue and Soil Total Arsenic Risks for Warm Climate
99.5% Reduction
100
90
Residue risk -playset only
Residue risk - decks & playsets
80
Cumulative Probability Density
Soil risk - playset only
70
Soil risk - decks & playsets
60
50
40
30
20
10
0
1.0E-12
1.0E-11
1.0E-10
1.0E-09
1.0E-08
Carcinogenic Risk
1.0E-07
1.0E-06
1.0E-05
1.0E-04
Figure D-7 Comparison of Residual & Soil Total Arsenic Risks for Warm Climate
Hand Wash
100
90
Soil risk - playset only
Cumulative Probability Density
80
70
Soil risk - decks & playsets
Residue risk -playset only
Residue risk - decks & playsets
60
50
40
30
20
10
0
1.0E-09
1.0E-08
1.0E-07
1.0E-06
Carcinogenic Risk
1.0E-05
1.0E-04
1.0E-03
Appendix E
Summary of Relative Bioavailability Studies
Prepared by Jonathan Chen, Ph.D 9-15-2003
SUMMARY OF RELATIVE BIOAVAILABILITY STUDIES
Prepared by Jonathan Chen, Ph.D 9-15-2003
The bioavailability of absorbed inorganic arsenic is dependent on the matrix in which it is exposed
to. Arsenic in drinking water is in a water-soluble form, and it is generally assumed that its
absorption from the gastrointestinal tract is nearly complete. Arsenic in soils, however, may be
incompletely absorbed because they may be present in water-insoluble forms or interact with other
constituents in the soil. The relative bioavailability of arsenic after it is been exposed (water
versus soil) was defined as the percentage of arsenic absorbed into the body of a soil-dosed animal
compared to that of animal receiving an single dose of arsenic in aqueous solution. This is a route
specific issue. The relative bioavailability through oral route for both arsenic in soil vs. arsenic in
water and arsenic in dislodgeable wood residue vs arsenic in water are discussed.
I. ARSENIC IN SOIL
I -A
STUDY SUMMARY
The arsenic relative bioavailability from soils were studied in different animal models . These
studies are summarized below.
I- A-1
Freeman et al. 1993
The relative bioavailability of arsenic from soil samples from Anaconda, Montana was
measured. After a fasting period of approximately 16 hours, prepubescent male and female
SPF New Zealand White rabbits (5/sex/group) were given a single oral (capsule)
administration of soil (3900ppm As) at three dose levels (0.2, 0.5, and 1.0 g of soil/kg,
corresponding to 0.78, 1.95 and 3.9 mg As/kg, respectively). Control groups included
untreated controls, and an intravenous sodium arsenate group (1.95 mg As/kg). The
relative bioavailability of arsenic in the soil was approximately 37 - 56 % (based on the As
concentration in the excreted urine).
Groen et al. 1993
I- A-2
Arsenic was administered as an intravenous solution (As2O5) or orally as As in soil to
groups of six beagle dogs, and urine was collected in 24-hour fractions for 120 hours.
After 120 hours, 88% ± 16% of the dose administered intravenously was excreted in the
urine, compared to only 7.0 ± 1.5% excreted in the urine after oral soil administration.
The calculated bioavailability of inorganic As from urininary excretion was 8.3 ± 2.0%.
I- A-3
Freeman et al. 1995
Oral absorption of arsenic in a group of three female Cynomolgus monkeys from a soluble
salt, soil, and household dust was compared with absorption of an intravenous dose of
sodium arsenate (Freeman et al. 1995). Mean absolute percentage bioavailability based on
urine arsenic excretion was reported at 67.6±2.6% (gavage), 19.2±1.5% (oral dust), and
13.8±3.3% (oral soil). Mean absolute percentage bioavailability based on blood arsenic
levels was reported at 91.3±12.4% (gavage), 9.8±4.3% (oral dust), and 10.9±5.2% (oral
soil). The relative bioavailabilities of arsenic in the dust and soil were approximately
28.4% and 20.4% respectively (based on urine).
I- A-4
USEPA Region 10, 1996
The relative bioavailability of arsenic and lead in soil or slag from the Ruston/North
Tacoma Superfund Site has been studied in immature swine that received one single oral
dose of soil or sodium arsenate (EPA, 1996). Following a 12 hour overnight fast, each
animal was given a single administration of the appropriate test material. Solutions of
sodium arsenate and lead acetate were administered separately and not mixed together
prior to administration. The group receiving environmental media received a single oral
administration od one of four quantities of soils at 25, 60, 100 or 150 mg soil/kg of body
weight (BW) (0.04, 0.10, 0.16, or 0.24 mg As/kg BW and 0.03, 0.08, 0.14, or 0.20 mg
pb / kg BW). Control groups include intravenous or gavage doses of solution arsenic,
untreated controls (received aqueous vehicle only), and an intravenous sodium arsenate
group (1.95 mg As/kg). Because several urine samples were lost during sampling
procedure, urinary arsenic excretion was not used as an biomarker in estimating
bioavailability. Based on the blood level of arsenic, the relative bioavailability of arsenic
(soil versus water) in the soil was 78% (56 - 111%).
I- A-5
USEPA Region 8, 1997
The bioavailability of arsenic in soil has been studied in juvenile swine that received daily
oral doses of soil or sodium arsenate (in food or by gavage) for 15 days (EPA 1997). The
soils were obtained from various mining and smelting sites and contained, in addition to
arsenic at concentrations of 100-300 µg/g, lead at concentrations of 3,000-14,000 µg/g.
The arsenic doses ranged from 1 to 65.4 µg/kg/day. The fraction of the arsenic dose
excreted in urine was measured on days 7 and 14 and the relative bioavailability of the
soil-borne arsenic was estimated as the ratio of urinary excretion fractions, soil
arsenic:sodium arsenate. The mean relative bioavailability of soil-borne arsenic ranged
from 0 to 98% in soils from seven different sites (mea±SD, 45% ±32). Estimates for
relative bioavailability of arsenic in samples of smelter slag and mine tailings ranged from7
to 5l% (mean±SD, 35%±27).
Roberts et al. 2001
I- A-6
The relative bioavailability of arsenic from selected soil samples was measured in a primate
model. Sodium arsenate was administered to five male Cebus apella monkeys by the
intravenous and oral routes, and urine and feces were collected over a four-day period.
Pharmacokinetic behavior of arsenic and the fractions of dose excreted in urine and feces
were consistent with previous observations in humans. Soil samples from four waste sites
in Florida (one from an electrical substation, one from a wood preservative treatment
(CCA) site, one from a pesticide application site, and one from a cattle dip vat site) were
dried and sieved. Soil doses were prepared from these samples and administered orally to
the monkeys. Relative bioavailability was assessed based on urinary excretion of arsenic
following the soil dose compared with excretion following an oral dose of arsenic in
solution. Relatively consistent bioavailability measurements were obtained among
monkeys given the same soil sample. Differences in bioavailability were observed for
different sites, with relative bioavailability ranging from 10.7±14.9% (mean±SD) to
24.7±3.2% for the four soil samples.
I- A-7
American Chemistry Council (ACC), 2003a.
The bioavailability of arsenic in soil affected by CCA-treated wood has been studied in
juvenile swine (ACC, 2003a). The soil was collected near the base of utility poles treated
with CCA Type C wood. The poles were installed on the site for around 5 years. The
arsenic concentration in the utility pole soil was 320 µg/g. Groups of five swine were
given oral doses of sodium arsenate or utility pole soil twice a day for 15 days. The
amount of arsenic absorbed by each animal was evaluated by measuring the amount of
arsenic excreted in the urine (as measured on days 8 to 9 and 10 to 11). The urinary
excretion fraction (UEF) (the ratio of the amount excreted per 48 hours divided by the
dose given per 48 hours) was calculated for sodium arsenate and the utility pole soil using
linear regression analysis. By using sodium arsenate as a relative frame of reference, the
mean RBA estimate for the soil affected by the CCA-treated wood is 49% (90th % CI =
41% - 58%).
The study design, the soil types and the results of these studies are summarized in Table I1.
I-B
DISCUSSION AND CONCLUSION
The issue has been discussed in the October 23- 25, 2001 FIFRA Scientific Advisory Panel
Meeting. In the meeting, the Agency as the panel members to comment on the choice of the
data set and value chosen for representation of the relative bioavailability of inorganic arsenic
from ingestion of arsenic-contaminated soil. The panel considered that a research is needed
to obtain data on the relative bioavailability of arsenic from soil contamination specifically
resulting from CCA-treated wood applications. Based on this consideration, ACC (2003)
conducted the study with soil contaminated directly from CCA-treated wood with the juvenile
swine model. This is the only study using soil that is contaminated with CCA-treated soil.
Although, only one soil type is involved in the study, after evaluating all available information,
the Agency decide to use 49% as the relative bioavailabilty value in the risk assessment.
II. ARSENIC IN WOOD RESIDUE
In the October 23- 25, 2001 FIFRA Scientific Advisory Panel Meeting, the panel member
also suggested the Agency to look into the relative bioavailability issue associated with the
absorption of arsenic from non-soil substances (such as wood chips or other buffer
material) that might be subject to incidental ingestion. For playground equipment,
the dislodgeable arsenic from CCA-treated wood become the primary
concern.
To address this issue, ACC sponsored a study (2003b). A study using juvenile
swine as test animals was performed to measure the gastrointestinal absorption of arsenic
in dislodgeable material obtained from the surface of chromated copper arsenate
(CCA)-treated wood. The CCA residue was collected from the surface of 1,456
CCA-treated boards of wood (Southern Yellow Pie or Ponderosa Pine) that had been
weathered in the environment for 1 to 4 years. The arsenic concentration in the
dislodgeable arsenic material was 3500 µg/g. Groups of five swine were given oral doses
of sodium arsenate or dislodgeable arsenic twice a day for 12 days. The amount of arsenic
absorbed by each animal was evaluated by measuring the amount of arsenic excreted in the
urine (as measured on days 6 to 7, 8 to 9, and 10 to 11). The urinary excretion fraction
(UEF) (the ratio of the amount excreted per 48 hours divided by the dose given per 48
hours) was calculated for sodium arsenate and the dislodgeable arsenic using linear
regression analysis. Using sodium arsenate as a relative frame of reference, the RBA
estimate for the test material is 29% (90th % CI = 26% - 32%).
The Agency consider this is a valid study and the result (29%) will be used as the relative
bioavailability of dislodgeable srsenic from CCA-treated wood.
III. REFERENCES
ACC, 2003a. CCA Workgroup, Relative Bioavailability of Arsenic in Soil Affected by
CCATreated Wood. Prepared by Veterinary Medical Diagnostic Laboratory College of
Veterinary Medicine. University of Missouri, Syracuse Research Corporation, Denver,
Colorado
.ACC, 2003b. CCA Workgroup, Relative Bioavailability of Dislodgeable Arsenic from
CCATreated Wood, Prepared by Veterinary Medical Diagnostic Laboratory Medicine.
University of Missouri, Syracuse Research Corporation, Denver, Colorado.
Freeman, G.B., Schoof, R.A., Ruby, M.V., Davis, A.O., Dill, J.A., Liao, S.C., Lapin, C.A., and
Bergstrom, P.D. 1995. Bioavailability of Arsenic in Soil and House Dust Impacted by
Smelter Activities Following Oral Administration in Cynomologus Monkeys.
Fundamental and Applied Toxicology 28:215-222
Freeman, GB., Johnson, J.D., Killinger, J.M., Liao, S.C., Davis, A.O., Ruby, M.V., Chaney, R.L.,
Lovre, S.C., and Bergstrom, P.D. 1993. Bioavailability of Arsenic in Soil Impacted by
Smelter Activities Following Oral Administration in Rabbits. Fundamental and Applied
Toxicology 21:83-88
Groen, K., Vaesen, H.A.G., Klest, J.I.G. deBar, J.L.M., von Ooik, T. Timmerman, A. and Vlug,
R.G. 1993. Bioavailability of Inorganic Arsenic from Bog Ore-Containing Soil in the
Dog. Environmental Health Perspective 102: 182-184.
Roberts, S.M.; Welmar, W.R.; Venson, J.R.; Munson, J.W.; and Bergeron 2001. Meausrement of
Arsenic Bioavailability from Soils Using a Primate Model. Unpublished.
US. EPA, 1996.. Bioavailability of Arsenic and Lead in Environmental Substrates. 1. Results of
an Oral Dosing Study of Immature Swine. Superfund/Office of Environmental
Assessment,Region 10, EPA 910/R-96-002,
US. EPA. 1997. Relative Bioavailability of Arsenic in Mining Wastes, Region 8, Document
Control No. 4500-88-AORH, 1997.
U.S. EPA, 2001. Children's Exposure to CCA-Treated Wood Playground Equipment and
CCAContaminated Soil (Final Report to SAP 9/27/01). Prepared by the Office of
Pesticide Programs Antimicrobial Division. Draft Version, September 27, 2001.
Appendix F
SAP Report No. 2001-12
FIFRA Scientific Advisory Panel Meeting,
October 23- 25, 2001, held at the Sheraton Crystal City
Hotel, Arlington, Virginia
A Set of Scientific Issues Being Considered by the
Environmental Protection Agency Regarding:
Preliminary Evaluation of the Non-dietary Hazard and
Exposure to Children from Contact with Chromated Copper
Arsenate (CCA)-treated Wood Playground Structures and
CCA-contaminated Soil.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OFFICE OF
PREVENTION, PESTICIDES, AND
TOXIC SUBSTANCES
December 12, 2001
MEMORANDUM
SUBJECT:
Transmittal of the Final Report for the FIFRA Scientific Advisory Panel (SAP)
Meeting Held October 23 - 25, 2001
TO:
Marcia E. Mulkey, Director
Office of Pesticide Programs
FROM:
Olga Odiott, Designated Federal Official
FIFRA Scientific Advisory Panel
Office of Science Coordination and Policy
Larry Dorsey, Executive Secretary
FIFRA Scientific Advisory Panel
Office of Science Coordination and Policy
THRU:
Vanessa T. Vu, Ph.D., Director
Office of Science Coordination and Policy
Please find attached the Report for the FIFRA SAP open meeting held October 23-25,2001:
Preliminary Evaluation of the Non-dietary hazard and Exposure to Children from Contact
with Chromated Copper Arsenate Treated Wood Playground Structures and
Contaminated Soil.
cc:
Stephen Johnson
Susan Hazen
Janet Andersen
Don Barnes (SAB)
James Jones
Denise Keehner
Elizabeth Leovey
Anne Lindsay
Douglas Parsons
Lois Rossi
Frank Sanders
Richard Schmitt
Margaret Stasikowski
OPP Docket
SAP Report No. 2001-12
FIFRA Scientific Advisory Panel Meeting,
October 23- 25, 2001, held at the Sheraton Crystal City
Hotel, Arlington, Virginia
A Set of Scientific Issues Being Considered by the
Environmental Protection Agency Regarding:
Preliminary Evaluation of the Non-dietary Hazard and
Exposure to Children from Contact with Chromated Copper
Arsenate (CCA)-treated Wood Playground Structures and
CCA-contaminated Soil.
SAP Report No. 2001-12
FIFRA Scientific Advisory Panel Meeting,
October 23 - 25, 2001, held at the Sheraton Crystal City
Hotel, Arlington, Virginia
A Set of Scientific Issues Being Considered by the
Environmental Protection Agency Regarding:
Preliminary Evaluation of the Non-dietary Hazard and
Exposure to Children from Contact with Chromated Copper
Arsenate (CCA)-treated Wood Playground Structures and
CCA-contaminated Soil.
Olga Odiott, M.S.
Designated Federal Official
FIFRA Scientific Advisory Panel
Date: December 12, 2001
Stephen M. Roberts, Ph.D.
FIFRA SAP Session Chair
FIFRA Scientific Advisory Panel
Date: December 12, 2001
NOTICE
This report has been written as part of the activities of the Federal Insecticide, Fungicide, and
Rodenticide Act (FIFRA), Scientific Advisory Panel (SAP). This report has not been reviewed
for approval by the United States Environmental Protection Agency (Agency) and, hence, the
contents of this report do not necessarily represent the views and policies of the Agency, nor of
other agencies in the Executive Branch of the Federal government, nor does mention of trade
names or commercial products constitute a recommendation for use.
The FIFRA SAP was established under the provisions of FIFRA, as amended by the Food
Quality Protection Act (FQPA) of 1996, to provide advice, information, and recommendations to
the Agency Administrator on pesticides and pesticide-related issues regarding the impact of
regulatory actions on health and the environment. The Panel serves as the primary scientific
peer review mechanism of the EPA, Office of Pesticide Programs (OPP) and is structured to
provide balanced expert assessment of pesticide and pesticide-related matters facing the Agency.
Food Quality Protection Act Science Review Board members serve the FIFRA SAP on an adhoc basis to assist in reviews conducted by the FIFRA SAP. Further information about FIFRA
SAP reports and activities can be obtained from its website at http://www.epa.gov/scipoly/sap/
or the OPP Docket at (703) 305-5805. Interested persons are invited to contact Larry Dorsey,
SAP Executive Secretary, via e-mail at dorsey.larry@.epa.gov.
ii
CONTENTS
PARTICIPANTS ------------------------------------------------------------------
1
PUBLIC COMMENTERS --------------------------------------------------------
3
INTRODUCTION -----------------------------------------------------------------
5
CHARGE ---------------------------------------------------------------------------
6
DETAILED RESPONSE TO THE CHARGE --------------------------------
15
ADDITIONAL PANEL RECOMMENDATIONS ---------------------------
55
REFERENCES --------------------------------------------------------------------
59
iii
Federal Insecticide, Fungicide, and Rodenticide Act
Scientific Advisory Panel Meeting
October 23 –25, 2001
Preliminary Evaluation of the Non-dietary Hazard and Exposure to Children from Contact
with Chromated Copper Arsenate (CCA)-treated Wood Playground Structures and CCAcontaminated Soil.
PARTICIPANTS
FIFRA SAP Chair
Stephen M. Roberts, Ph.D., Director, Center for Environmental and Human Toxicology,
University of Florida
Scientific Advisory Panel Members
Fumio Matsumura, Ph.D., Institute of Toxicology and Environmental Health, University of
California at Davis
Mary Anna Thrall, D.V.M., Department of Pathology, College of Veterinary Medicine &
Biomedical Sciences, Colorado State University
FQPA Science Review Board Members
John L. Adgate, Ph.D., University of Minnesota School of Public Health, Division of
Environmental and Occupational Health
Michael Bates, Ph.D., Visiting Researcher, School of Public Health, University of California,
Berkeley
James V. Bruckner, Ph.D., Department of Pharmaceutical and Biomedical Sciences, College of
Pharmacy, University of Georgia
Karen Chou, Ph.D., Institute for Environmental Toxicology, Institute of International Health,
Dept. of Animal Science, Michigan State University
Harvey Clewell, M.S., ENVIRON International Corporation, Ruston, Louisiana
M. Rony Francois, M.D., Ph.D.c, University of South Florida, College of Public Health
Natalie Freeman, Ph.D., Department of Environmental and Community Medicine, Robert Wood
Johnson Medical School, University of Medicine and Dentistry of New Jersey
1
Gary L. Ginsberg, Ph.D., Connecticut Department of Public Health, Environmental
Epidemiology, and Occupational Health, CT Dept. of Public Health
Terry Gordon, Ph.D., NYU School of Medicine
Steven Heeringa, Ph.D., Director, Statistical Design and Analysis, Institute for Social Research
University of Michigan
Claudia Hopenhayn-Rich, M.P.H., Ph.D., Department of Preventive Medicine and
Environmental Health, University of Kentucky
John Kissel, Ph.D., Department of Environmental Health, School of Public Health and
Community Medicine, University of Washington
Michael J. Kosnett, M.D., M.P.H., Division of Clinical Pharmacology and Toxicology,
University of Colorado Health Sciences Center
Peter S.J. Lees, Ph.D., C.I.H., Johns Hopkins University, Bloomberg School of Public Health,
Department of Environmental Health Sciences, Division of Environmental Health Engineering,
Ross B. Leidy, Ph.D., Director, Pesticide Residue Research Laboratory, Department of
Toxicology, North Carolina State University
Peter D.M. Macdonald, D.Phil., Department of Mathematics and Statistics, McMaster
University, Hamilton, Ontario, Canada
David W. Morry, Ph.D., Office of Environmental Health Hazard Assessment,
California Environmental Protection Agency
Paul Mushak, Ph.D., PB Associates, Durham, NC
Xianglin Shi, Ph.D., Pathology and Physiology Research Branch, National Institute for
Occupational Safety and Health, Morgantown, WV
Andrew Smith, SM, ScD, Director, Environmental Toxicology Program, Maine Department of
Human Services
Helena Solo-Gabriele, Ph.D., P.E., Department of Civil,Arch., and Environmental Engineering,
University of Miami, FL
Jacob J. Steinberg, M.D., Albert Einstein College of Medicine, Director, Autopsy Division,
Director, Residency Training Program, Environmental Medicine and Pathology Laboratory,
Montefiore Medical Center, N.Y.
Miroslav Styblo, Ph.D., Department of Pediatrics, School of Medicine, and Department of
2
Nutrition, School of Public Health, Department of Pediatrics, University of North Carolina
John Wargo, Ph.D., Environmental Policy and Risk Analysis, Yale University, CT
PUBLIC COMMENTERS
Oral statements were made by:
Jane Houlihan, Environmental Working Group, Washington, D.C.
Cristopher Williams, Ph.D., Ecology and Environment Inc.,Tallahassee, FL
Ligia Mora-Applegate, M.S.P., M.P.A., M.P.H., Florida Department of Environmental
Protection
Pascal Kamdem, Ph.D., Michigan State University, on behalf of American Forest and Paper
Association
H. Vasken Aposhian, Ph.D., University of Arizona, on behalf of Arch Chemicals, Inc.
Jay Feldman, Beyond Pesticides / National Coalition Against the Misuse of Pesticides
Yvette Lowney, M.P.H., Exponent, on behalf of the American Chemistry Council
Barbara Beck, Ph.D., DABT, Gradient Corporation, on behalf of Osmose and Arch Chemicals,
Inc.
Bill Walsh, Healthy Building Network, Washington, DC
John Butala, M.S., Toxicology Consultants, Inc., on behalf of American Chemistry Council
Arsenical Wood Preservatives Task Force
Joyce Tsuji, Ph.D., Exponent, on behalf of American Forest and Paper Association
Scott Conklin, Universal Forest Products, Inc.
Robert Turkewitz, Ness, Motley, Loadholt, Mount Pleasant, SC
Steven Lamm, M.D., Consultants in Epidemiology & Occupational Health, Inc., Washington,
DC
3
Written statements were made by:
The Accord Group, on behalf of Osmose and Arch Chemicals, Inc.
Mr. Marc Leathers, Leathers & Associates, Inc.
Ligia Mora-Applegate, M.S.P., M.P.A., M.P.H., Florida Department of Environmental
Protection
4
INTRODUCTION
The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), Scientific Advisory Panel
(SAP) has completed its review of the set of scientific issues being considered by the Agency
pertaining to its review of the Office of Pesticide Programs' (OPP) Preliminary Evaluation of the
Non-dietary Hazard and Exposure to Children from Contact with Chromated Copper Arsenate
(CCA)-treated Wood Playground Structures and CCA-contaminated Soil. Advance notice of the
meeting was published in the Federal Register on September 19, 2001. The review was
conducted in an open Panel meeting held in Arlington, Virginia, October 23- 25, 2001. The
meeting was chaired by Stephen M. Roberts, Ph.D. Ms. Olga Odiott served as the Designated
Federal Official.
The scientific issues addressed by the FIFRA SAP were complex and varied. Panel members
were selected to serve because of their expertise in one or more of the subject areas being
discussed. The Panel was asked to evaluate the scientific soundness and OPP’s evaluation of the
exposure and hazard data available to the Agency for CCA. Specifically, the Panel was asked to
1) review the exposure scenarios and hazard endpoints that the Agency intends to use in its
CCA-risk characterization for children; and 2) provide recommendations concerning additional
data needed to reduce the uncertainties of this risk characterization.
5
CHARGE
Issue: Short- and Intermediate-term Endpoint Selection for Inorganic Arsenic
For inorganic arsenic, the data of Franzblau et al (1989) and Mizuta et al (1956) using a
LOAEL value of 0.05 mg/kg/day is proposed for selection of short-term and
intermediate-term incidental oral endpoints as well as short-term and intermediate-term
dermal endpoints. An acceptable Margin of Exposure value of 100 is also proposed.
The acceptable Margin of Exposure value includes a 10x factor for intraspecies variation
as well as a 10x factor for use of a LOAEL value and the severity of the effects observed
in the Mizuta study.
Question 1: Please comment on the Agency’s selection of the 0.05 mg/kg/day
LOAEL value for use in assessing risks to the general population as well as children
from short-term and intermediate-term incidental oral and dermal exposures, and
the appropriateness of the use of a 10x factor for severity of the toxic effects
observed in the Mizuta study. Please provide an explanation and scientific
justification for your conclusions as to whether the presented data are adequate or
whether other data should be considered for selection of this endpoint.
Issue: Relative Bioavailability of Inorganic Arsenic
The bioavailability of inorganic arsenic is dependent on the matrix in which it exists. For
purposes of this discussion, the relative bioavailability of inorganic arsenic after
ingestion of arsenic-contaminated soil is defined as the percentage of arsenic absorbed
into the body from soil compared to that of arsenic administered in drinking water.
Arsenic in drinking water is in a water-soluble form, and bioavailability by this route is
high (i.e. 95-100%). Arsenic in soil, however, has reduced bioavailability due to
existence in a water-insoluble form or its interaction with other soil constituents that
impair absorption.
The available data on urinary and fecal recovery of arsenic after an intravenous dose of
sodium arsenate in experimental animals compared to recovery after administration of
sodium arsenate to experimental animals in soil was examined. Based on these data, a
value of 25% bioavailability was selected for arsenic from soil ingestion. This value is
based upon the data of Roberts et al. (2001) and Freeman et al. (1995) using non-human
primates. These data were felt to best represent relative bioavailability of inorganic
arsenic in soil based on the use of non-human primates and the physiological similarity in
the pattern of metabolism with humans, and the use of CCA-contaminated soil in the
study for estimation of bioavailability.
6
Question 2: Please comment on the choice of this data set and value chosen for
representation of the relative bioavailability of inorganic arsenic from ingestion of
arsenic-contaminated soil. Please discuss the strengths and weaknesses of the
selected data and also provide an explanation as to whether this 25% value is
appropriate for estimation of bioavailability in children.
Issue: Dermal Absorption Value for Inorganic Arsenic
A value of 6.4% for the dermal absorption of arsenic was selected to represent
absorption from dermal contact with inorganic arsenic. This value is based upon the data
of Wester et al. (1993) and represents percent absorbed dose of arsenic applied to the
skin in a water solution. Although this value is slightly higher than the value of 4.5%
obtained for arsenic applied in soil, the mean values for absorption from water and soil
both showed significant variability (i.e. 6.4% " 3.9% in water, 4.5% "3.2% in soil) such
that use of the 6.4% dermal absorption value was selected. It is observed in this study
that a higher dose on the skin resulted in lower dermal absorption as noted above, but the
data in this study suggests sufficient variability in the absorption such that use of the
6.4% dermal absorption value is sufficiently but not overly conservative.
Question 3: Please comment on the selection of the value of 6.4% for dermal
absorption of inorganic arsenic and whether or not this value will be appropriate
for use in all scenarios involving dermal exposure to arsenic from CCA-treated
wood, including children’s dermal contact with wood surface residues and
contaminated soils.
Issue: Selection of Hazard Database for Hazard Characterization of Inorganic
Chromium in CCA-Treated Wood
Hazard data show clearly that Cr (VI) demonstrates more significant toxicity than Cr
(III). However, there is little data delineating the valence state of chromium in
compounds that leach from in-service CCA-treated wood (Lebow, 1996). Interconversion
of Cr (VI) and Cr (III) in the environment is observed (Cohen et al., 1999), and at least
one study has reported measurable levels of hexavalent chromium in soils (Lebow,
1996). In-service CCA-treated wood contains mainly chromium (III), due to reduction of
chromium (VI) during fixation. However, when fixation conditions are not ideal or when
storage temperatures are low, Cr (VI) is observed to be present in leachate from the
treated wood and in addition, conditions in some soil types can result in conversion of
leached Cr (III) to Cr (VI).
Question 4: As available monitoring data do not differentiate among chromium
species found in CCA dislodgeable residues on wood surfaces and in soils, and as Cr
(VI) is the more toxic species of chromium, please comment on whether use of the
7
hazard data for chromium (VI) is the best choice for characterizing hazard and risk
from exposure to chromium as a component of CCA-treated wood. Please provide a
scientific explanation and justification for your recommendation on the choice of
either the chromium (III) or chromium (VI) hazard database.
Issue: Short- and Intermediate-term Endpoint Selection for Inorganic Chromium
For inorganic chromium (VI), OPP proposes using the developmental toxicity study of
Tyl (MRID 42171201) with a NOAEL value of 0.5 mg/kg/day [0.12 mg/kg/day
chromium equivalents] and an MOE of 100 (10x for interspecies variation, 10x for
intraspecies variation) for selection of short-term and intermediate-term incidental oral
endpoints.
Question 5: Please comment on the Agency’s selection of the 0.5 mg/kg/day NOAEL
value for use in assessing risks to the general population as well as children from
short-term and intermediate-term incidental oral exposures to inorganic chromium
as contained in CCA-treated wood. Please provide an explanation and scientific
justification for your conclusions as to whether the presented data are adequate or
whether other data should be considered for selection of these endpoints.
Issue: Selection of Endpoints for Dermal Risk Assessments for Inorganic Chromium
Dermal exposure to chromium has been demonstrated to produce irritant and allergic
contact dermatitis, and chromium is also one of the most common contact sensitizers in
males in industrialized countries (IRIS, 2000). The relative potency of Cr (VI) and Cr
(III) in causing dermal effects has been estimated to differ by approximately 50-fold
(Bagdon,1991) but both produce irritation and dermal sensitization. In the OPP HIARC
review of selection of dermal toxicity endpoints, it was concluded that skin irritation and
skin allergenicity are the primary effects of concern from dermal exposure to Cr(VI), as
these effects are the predominant response from dermal exposure to inorganic chromium.
Thus, endpoints based on systemic effects from dermal exposure were not selected.
Question 6: Please comment on whether the significant non-systemic dermal effects
from dermal exposure to inorganic chromium should form the basis of dermal
residential risk assessments, and, if so, how the Agency should establish a dermal
endpoint for such an assessment.
Issue: Selection of Parameters and Methodology for Characterizing Child Exposures
OPP intends to develop realistic exposure scenarios and dose estimates for characterizing
potential dermal/oral ingestion exposures to children in playground settings from contact
with dislodgeable As and Cr residues on CCA-treated wood playground structures and in
CCA-contaminated soils. In keeping with EPA policy, OPP would like its estimates to
8
characterize both the middle and upper end of the range of potential exposure values.
(The “high end” of exposure is defined as a level of exposure which is likely to be higher
than experienced by at least 90% of the population, but not higher than the level
experienced by the maximally exposed individual.) Following EPA guidance on
conducting exposure assessments, OPP intends to rely on “mean value” (central
tendency) data for calculating the lifetime average daily doses (LADDs) used for the
cancer assessment, and “maximum value” (high end) data for calculating the average
daily doses (ADDs) used for the non-cancer assessment.
OPP expects to use a combination of central tendency and high end values for the
different parameters of the exposure equations, as identified below.
Exposure Parameters Proposed for Use in Conducting the Child Exposure Assessment
General Variables:
Scenario Specific Variables:
C
C
C
Dermal Contact with Soil
Oral Ingestion of Residues
from Hand-to-Mouth
Contact with Wood
Oral Ingestion of Soil
Residues
Age
3 yr old
Body Weight
15 kg
central tendency
central tendency
2
Surface Area:
hands, arms, legs
1640 cm
3 fingers
20 cm2
central tendency
Playground activity:
hours / day
1 hr
central tendency
days / year
130 days
central tendency
years / lifetime
6 yrs out of a
75 yr lifetime
central tendency
Soil Adherence Factor
1.45 mg/cm 2
central tendency
Exposure time
(hrs/day spent for
hand-to-mouth activity)
1 hr/day and
3 hrs/day
central tendency and
high end
Hand-to-Mouth Frequency
(events/hour)
9.5 events/hr and
20 events/hr
central tendency and
high end
Fraction Ingestion
50% removal
efficiency
central tendency
Soil Ingestion Rate
100 mg/day and
400 mg/day
central tendency and
high end
high end
Question 7. Please comment on whether OPP’s choices of central tendency and high
end values for different parameters should, collectively, produce estimates of the
middle and high end of the range of potential exposures. If the Panel thinks that
OPP’s approach may not estimate the high ends of the exposure range (because it
produces values that are either higher or lower than the upper end of the exposure
9
range), please comment on what specific values should be modified to produce
estimates of the high end of potential exposure.
EPA recognizes that there are many parameters that affect the level of potential exposure
and that each of these parameters may vary. Probabilistic (e.g., Monte Carlo) techniques
are capable of using multiple data sets which reflect the variability of parameters to
produce estimates of the distribution of potential exposures. OPP has identified a
number of data sets that contain information on the variability of parameters affecting the
levels of exposure to CCA residues experienced by children as a result of their
playground activities. Nonetheless, OPP intends to develop deterministic estimates of
potential exposure using selected values (either central tendency or high end) for
different parameters, in such a manner that the estimates describe both the middle and
high end of the range of exposures.
Question 8: Please comment on whether the existing data bases on the variability of
the different parameters affecting potential exposure are adequate to support the
development of probabilistic estimates of potential exposure. If the Panel regards
the data bases as adequate for that purpose, please identify which parameters
should be addressed using a distribution of values and which data bases should be
used to supply the distribution for particular parameters.
Issue: Transfer of Residues from Wood Surface to Skin
In lieu of appropriate data on residue transfer from wood to skin surfaces, OPP proposes
to rely on assumptions for residue transfer from turf as a surrogate. A one-to-one
relationship is assumed between the transferable residues on turf and the surface area of
the skin after contact (i.e., if the transferable residue on the turf is 1 mg/cm 2, then the
residue on the human skin is also 1 mg/cm 2 after contact with the turf). This is based on
OPP’s Residential SOP’s (April, 2000). OPP plans to apply this one-to-one relationship
to the current assessment, assuming a one-to-one relationship between the dislodgeable
residues on the wood surface and the surface of the skin after contact.
Question 9: OPP is assuming that a one-to-one relationship applies to the transfer
of residues from wood to skin. The Panel is asked to address whether this is a
reasonable assumption, and if not, to provide guidance on other approaches.
Issue: Selection of a Soil Adherence Factor
The Soil Adherence Factor (AF) is defined as the amount of soil which adheres to the
skin. The AF is highly dependent on the soil type, moisture content of soil and skin,
amount of time the soil contacts the skin, and human activities. OPP adopted a dermal
exposure scenario for children touching CCA-contaminated soil which relies on an AF of
1.45 mg/cm 2 (U.S.EPA’s Superfund RAG, 1989) for hand contacting commercial potting
10
soil in lieu of playground soil. A recently drafted report (U.S.EPA’s Superfund RAG,
Part E., Supplemental Guidance for Dermal Risk Assessment, draft, 2000), recommended
an activity-specific surface area weighted AF value for a child resident at a day care
center (1 to 6 years old) of 0.2 mg/cm 2.
Question 10: The Panel is asked to comment on whether the proposed AF of 1.45
mg/cm2 for hand contact with commercial potting soil is a realistic value for use in
estimating the transfer of residues from playground soil to skin in this assessment.
Issue: Variability of Residue Data Available for Soil and Wood.
The soil and wood residue data being considered for this assessment has been generated
over the last 25 years. There are several variables influencing the consistency of the
data:
- Data were gathered and analyzed by several different research laboratories
- Data were collected at different geographic sites
- Differences in wood types and treatments between data sets
Additionally, the leaching rates of arsenic and chromium (to both the wood surface and
the soil) are highly dependent on factors such as wood type, degree of weathering, age of
wood, moisture content, pressure treatment process and retention time, use of
coatings/sealants, and variations in the analytical and sampling techniques between
laboratories.
OPP summarized the residue data by selecting and recommending some of the mean and
maximum values from each study in order to compare the degree of leaching from the
wood and the level of contamination in the soils. The “mean” data will be used to
develop the lifetime average daily doses (LADDs) for the cancer assessment, and
“maximum” data used in developing the average daily doses (ADDs) for the non-cancer
assessment.
Question 11: OPP will need to calculate intermediate-term, and possibly long-term
exposures in this assessment using available wood/soil residue data. The Panel is
asked to recommend a credible approach for selecting residue data values for use in
OPP’s risk assessment, taking into consideration the inherent variability of the data
sets. Please advise us on which values are best for representing central tendency
and high-end exposures. Also, the Panel is asked to discuss the feasibility of
combining data from individual data sets.
Issue: Combining Multiple Exposure Scenarios into a Comprehensive Estimate of Risk
Children playing on playgrounds containing CCA-treated wood structures will be
exposed to arsenic and chromium residues on wood surfaces and in soils via oral and
dermal routes. OPP has discussed four proposed exposure scenarios individually in the
exposure assessment; however, to adequately assess the risks to children from exposure
11
to arsenic and chromium residues through playground contact with wood and soil media,
all four scenarios must be considered concurrently.
Question 12: Does the Panel have any recommendations for combining the four
scenarios (oral/wood, dermal/wood, oral/soil, dermal/soil) such that a realistic
aggregate of these exposure routes may be estimated?
Issue: Inhalation Exposure Potential from Wood/Soil Media
The Agency has selected a NOAEL value of 2.4 x 10-4 mg/m 3 taken from the 1998 IRIS
update for Cr(VI) using the study of Lindberg and Hedenstierna (Arch Environ Health
38(6):367-374) who observed ulcerations, perforations of the nasal septum and
pulmonary function changes in 104 workers (85 males, 19 females) exposed in chrome
plating plants at a concentration of 7.14 x 10-4 mg/m 3. The NOAEL value selected is
intended to represent an endpoint for use in inhalation risk assessments representative of
any duration of exposure.
OPP does not propose to evaluate potential exposures via the inhalation route for the
child playground exposure assessment. The Agency anticipates that the inhalation
potential from contact with either CCA-treated wood or CCA-contaminated soil is
negligible. Neither arsenic As(V) nor chromium Cr(VI) residues are volatile on the
surfaces of treated wood, or readily available as respirable airborne particulate
concentrations. During play activities in CCA-contaminated soil, any airborne soilbound residues that a child might inhale through the nose or mouth are not anticipated to
contribute significantly to the overall exposure (i.e., exposure will be insignificant
compared to the oral dose attributed to soil ingestion or hand-to-mouth activities).
Question 13: Can the Panel comment on whether OPP should conduct a child
playground inhalation exposure assessment, taking into consideration the hazard
profile for chromium (VI) as an irritant to mucous membranes? If so, can the Panel
comment on whether the endpoint described above is appropriate for assessing the
risk to children from such an exposure?
Issue: Consideration of Buffering Materials as a Source of Exposure
The CPSC specifies suitable loose-fill surfacing materials (e.g., wood chips/mulch, sand,
gravel, and shredded rubber tires) for use under and around public playground equipment
as shock-absorbing buffers (i.e., “buffering materials”) to protect children from injury
during a fall. (Handbook for Public Playground Safety, U.S. CPSC, Pub. No. 325) .
Concerns surrounding use of these buffers include the potential for CCA compounds to
leach from the CCA-treated playground equipment and absorb into the buffering
materials. In addition, these buffers may include wood mulch products originating from
recycled construction and demolition (C&D) debris that may contain varying quantities
of CCA-treated wood. Coupling CCA-treated playground equipment with playground
12
barriers made from recycled wood mulch containing CCA-treated wood may increase
background levels of arsenic and chromium, posing greater human exposure and health
concerns.
Leaching studies conducted in Florida by Townsend et al. (2001) on new CCA-treated
wood samples (wood blocks, chipped wood mulch, and sawdust) indicated that the
concentrations of metals in leachate solutions were higher for wood processed into
chips/mulch or sawdust over wood blocks. The degree to which wood leaches appears to
be dependent on particle size since wood chips/mulch have increased surface areas
available for leaching, and consequently exposure, over dimensional lumber.
Currently there are limited data available which adequately address the effects of
leaching of CCA-treated wood compounds from playground structures to buffering
materials used under and around these structures. A recent report released by Florida’s
Alachua County Board of County Commissioners (2001) presents soil and mulch data
from limited arsenic sampling conducted by Environmental Protection Department staff
at five county owned parks. Tire chip and wood mulch buffering materials sampled at
half-depth (2"-6") from areas immediately adjacent to CCA wood playground borders,
playground posts, and within playground areas (between borders/posts) yielded arsenic
concentrations for wood mulch of 43.1 - 61.2 mg/kg ( border) and 0.5 mg/kg (play areas),
and for tire chips 3.5 - 70.3 mg/kg ( border), 10.3 - 80.3 mg/kg (posts) and 0.4 - 0.9
mg/kg (play areas). Each park had a liner in place between the mulch material and the
bare soil.
Question 14: Data on the effectiveness of reducing exposure by using buffering
materials are limited. Does the Panel have recommendations as to whether
additional studies to obtain this information are warranted? Does the Panel have
suggestions on how OPP can best evaluate child exposures attributed to contact with
CCA-contaminated buffering materials ?
Issue: Effectiveness of Stains/Sealants/Coatings at Reducing Leaching of CCA Compounds
from Treated Wood
Several researchers have reported that stains/sealants/coatings can reduce the rate of
leaching of CCA compounds from treated wood and that the effectiveness of these
coating materials over time varies greatly, depending on the type of surface coating used
and environmental conditions effecting the wood. Stilwell (1998) reported over a 95%
reduction in dislodgeable arsenic residues from CCA-treated wood surfaces coated with
polyurethane, acrylic or spar varnish, and an average of 90% reduction for oil-based alkyl
resins for samples tested one year after a sealant was applied. CDHS (1987) reported
96%, and 82% reductions in dislodgeable arsenic from stained CCA-treated wood
surfaces after one month and 2 years, respectively. Lebow and Evans (1999) reported
that staining CCA-treated wood surfaces reduced leaching of arsenic by 25%.
13
Question 15: The Panel is asked to comment as to whether stains, sealants and other
coating materials should be recommended as a mitigation measure to reduce
exposure to arsenic and chromium compounds from CCA treated wood. If so, can
the Panel comment on the most appropriate way for the Agency to recommend
effective coating materials when the current data on long-term performance are
limited and sometimes inconsistent, and should the Agency specify a time interval
for the re-application of these selected coating materials? Can the Panel make
recommendations for additional studies?
14
DETAILED RESPONSES TO THE CHARGE
Question 1
Please comment on the Agency’s selection of the 0.05 mg/kg/day LOAEL
value for use in assessing risks to the general population as well as children
from short-term and intermediate-term incidental oral and dermal
exposures, and the appropriateness of the use of a 10x factor for severity of
the toxic effects observed in the Mizuta study. Please provide an
explanation and scientific justification for your conclusions as to whether the
presented data are adequate or whether other data should be considered for
selection of this endpoint.
Recommendation
There was consensus by the Panel that 0.05 mg As/kg per day is an appropriate LOAEL for
short- (1 to 30 day) and intermediate- (31 to 180 day) human ingestion of the chemical. The
majority of Panel members expressing an opinion recommended a margin of exposure (MOE) of
30 from this LOAEL to afford protection from non-cancer health effects. Some Panel members
thought an MOE of 10 would be adequate.
Discussion
Both Mizuta et al. (1956) and Fanzblau and Lilis (1989) described symptoms and clinical signs
of arsenic poisoning in persons believed to have consumed 0.03 – 0.08 mg/kg per day for up to
several weeks. Confidence in these dose estimates is low. Mizuta et al. (1956) did not provide
information on their analytical method or on the basis for estimating the extent of arsenic
consumption [from soy sauce] in patients experiencing arsenic toxicity. The information in
Franzblau and Lilis (1989) pertaining to dose is derived in part from a retrospective estimate of
water ingestion rates by two individuals who sporadically utilized an arsenic contaminated well.
Despite reservations about the dose estimates from these two studies, confidence in 0.05 mg/kg
per day as an appropriate LOAEL is quite high in that several other clinical studies have
reported the emergence of adverse signs and symptoms associated with the ingestion of
inorganic arsenic at similar doses. These include accounts of gastrointestinal disturbances and
less commonly mild peripheral neuropathy in individuals consuming medicinal preparations
such as Fowler’s solution or liquor arsenicalis at doses of 5 to 10 mg of arsenite per day over a
period of days to months (Stockman, 1902; Pope, 1902; Harter and Novitch, 1967). Daily doses
of arsenic that were probably in the range of 1 to 5 mg arsenite per day for weeks to months
resulted in gastrointestinal and peripheral neurological findings during the Manchester beer
epidemic of 1900 (Reynolds, 1901; Kelynack and Kirby, 1901). Arsenic exposure in drinking
water for 1 to 4 months was observed to result in gastrointestinal, neurological, and skin
symptoms at doses estimated to be > 0.05 mg/kg per day (Wagner, 1979 as summarized in
Benson, 2001). While each of these studies individually has limitations in terms of establishing
a LOAEL, there is reassurance in the relative consistency of the LOAEL value they collectively
provide. Confidence is further enhanced by the large overall number of subjects, the ethnic
diversity of the subjects, and the inclusion of potentially sensitive subpopulations (including
15
children) across studies.
Several members of the Panel expressed the opinion that the severity of symptoms noted in some
patients near or moderately above a LOAEL of 0.05 mg/kg per day warranted a full uncertainty
factor of 10. Reports of peripheral neuropathy, gastrointestinal bleeding, liver damage, low
blood counts, CNS dysfunction, and abnormal electrocardiograms were mentioned as examples
of signs and symptoms of concern in these patients. Humans appear to be more sensitive than
most laboratory animals to arsenic toxic effects, and there is little information on the shape of
the dose-response curve for these effects in humans. Without knowledge of the dose-response
relationships, it is difficult to forecast acceptable margins of safety. This uncertainty contributed
to the recommendation that a 10X uncertainty factor be applied to the LOAEL of 0.05
mg/kg/day.
The Panel was divided on whether the MOE should include an additional uncertainty factor. The
majority of Panel members expressing an opinion recommended that a MOE include an
additional intraspecies uncertainty factor of 3 to provide for protection of children. They pointed
out that there may be subpopulations of children at special risk of arsenic toxicity, such as
individuals with concomitant toxic exposures and/or vitamin and nutritional deficiencies that
might impact arsenic kinetics. They noted that there is a paucity of information on the
toxicokinetics of arsenic and its metabolites in children, and that it is unclear whether there are
age-dependent differences in GI absorption or biotransformation of arsenic that might influence
toxicity. It was acknowledged that data available at present generally indicate that responses of
children and adults to arsenic do not differ significantly qualitatively or quantitatively.
However, the opinion was expressed that these data pertain largely to effects on the skin, and
that the immature central and peripheral nervous systems may be quite another matter. Short
and intermediate term exposure to sufficiently high doses of arsenic are neurotoxic in adults, and
data offering insight as to the arsenic doses associated with neurological effects in children were
viewed by these Panel members as lacking. Specifically, an absence of adequate studies
monitoring neurological indices in children exposed at or near the proposed arsenic LOAEL was
cited. Some Panel members expressed concern for childhood exposure to arsenic in combination
with other neurotoxic metals, and for synergy with other toxicants. Toxicity data on
combinations of arsenic and other toxicants are extremely limited, and some Panel members
questioned whether a NOAEL developed for inorganic arsenic alone is applicable under
circumstances of exposure to other components of CCA.
Some Panel members argued that an additional intraspecies uncertainty factor of 3X was not
required, and that an overall MOE of 10 would be adequate to protect human health. It was
noted that an MOE of 30 would identify doses above 0.0017 mg/kg per day as having the
potential to produce adverse non-cancer effects with exposures of 180 days or less. For a 15 kg
child, 0.0017 mg/kg per day is equivalent to 25 micrograms of arsenic per day. Since it is
estimated that the background diet of a 3 year old includes approximately 5 micrograms of
inorganic arsenic (NRC, 1999), the 30-fold margin applied to a 15 kg child would be akin to
expressing concern regarding short- or intermediate-term doses greater than an additional 20
micrograms of arsenic per day. There are no data demonstrating acute or subchronic noncancer
effects at this approximate level of exposure. The United States experience with respect to
16
existing levels of arsenic in drinking water was cited as evidence for this. The US EPA has
estimated that there are in excess of 1200 public drinking water systems in the United States that
deliver drinking water with arsenic concentrations in excess of 20 ug/L (US EPA, 2001). Since
the level of water consumption by some 3 year olds is 60 ml/kg (90 th percentile estimate) (NRC,
2001), there appear to be many communities in the United States where young children have
already been consuming >25 micrograms day. There are no reliable reports in the medical
literature documenting or suggesting that adverse health effects from arsenic have occurred in
these children. Several health surveys conducted in U.S. communities where the arsenic
concentration in drinking water was several hundred micrograms per liter have also not detected
adverse non-cancer effects (Harrington et al., 1978; Kreiss et al., 1983; Southwick et al., 1983).
It was pointed out that both the Agency for Toxic Substances and Disease Registry (ATSDR)
and U.S. EPA Region 8 have established health criteria for short- and intermediate-term
exposure to arsenic of 0.005 mg/kg-day or higher, which is equivalent to an MOE of 10 or less
[from a LOAEL of 0.05 mg/kg-day]. Finally, it was noted by one Panel member that clinical
studies on children exposed to arsenic in drinking water associated the increased severity of
observed multisystemic adverse effects in children compared to adults to a higher dose rate in
children, and not to intrinsically increased susceptibility (Zaldivar, 1977; Zaldivar and Gullier,
1977; Zaldivar and Ghai, 1980).
Some Panel members cautioned that exposures above the MOE do not necessarily mean that
health effects will occur and that the Agency should use the MOE in a screening level capacity
only. That is, firm conclusions on the presence or absence of health effects should not be drawn
solely on the basis of doses calculated to exceed the MOE.
Question 2:
Please comment on the choice of this data set and value chosen for
representation of the relative bioavailability of inorganic arsenic from
ingestion of arsenic-contaminated soil. Please discuss the strengths and
weaknesses of the selected data and also provide an explanation as to
whether this 25% value is appropriate for estimation of bioavailability in
children.
Recommendation
Panel members expressed a diversity of opinions regarding the designation of 25% as a value for
the estimated relative bioavailability of inorganic arsenic from ingestion of arsenic-contaminated
soil. Several members of the Panel felt that EPA should consider alternatives to a fixed value of
25% for the relative bioavailability of arsenic in soil in the vicinity of CCA contamination, while
others felt that 25% was a reasonable interim value. Many members suggested an interim value
of 50%. Several Panel members recommended that a range of values be considered: for some
the suggested range was 25 to 50%, while another member suggested consideration of the full
range of bioavailability for arsenic in soil reported in the literature (near zero to 98%).
In addition to oral absorption of arsenic from soil, consideration should be given to absorption of
arsenic from nonsoil substances (such as wood chips or other buffer material) that might be
subject to incidental ingestion.
17
Research is needed to obtain data on the relative bioavailability of arsenic from numerous sites
that encompass the broad range of soil types and arsenic contamination specifically resulting
from CCA-treated wood applications. These studies should be conducted in appropriate animal
models preferably at doses that simulate the anticipated level of exposure of children playing on
or around structures or sites subject to CCA contamination.
Discussion
There is general scientific consensus that a number of physical, chemical, and biological factors
may impact the extent of gastrointestinal absorption of a substance present in ingested soil
relative to absorption of the same substance ingested in solution. For arsenic, as with several
other metals, solubility of the form of arsenic present in soil is a key factor, such that increased
solubility or extractability of the metal from soil to an aqueous solution is positively correlated
with increased absorption. Chemical and physical factors influencing the solubility or
extractability of arsenic from the soil include 1) the molecular form of the arsenic species; 2) the
nature of its chemical and/or physical interaction with the constituents of the soil matrix (e.g.,
chemical bonding, sorption, complexation, rinding, or encapsulation); and 3) the size, porosity,
compaction, and surface area of the arsenic-containing soil particulates or agglomerations.
Biological factors may also influence the absorption of an ingested metal present in soil,
including 1) the species-specific metabolism of the metal, including metabolism by microflora
within the gastrointestinal tract (Hall et al., 1997), 2) the physical condition of the animal at the
time of ingestion (e.g., the effect of drugs, physical stress, toxins, nutritional perturbations, or
disease states on the animal’s physiology), 3) the presence of other ingested material (food,
drugs, or other substances) in the intestinal tract, and 4) in some cases the age and/or
developmental stage of the animal. The dose regimen that characterizes the ingestion of the
metal and the soil matrix may also exert influence on the absorption, in terms of either absolute
amounts or the percent of the dose administered. For example, data on absorption of lead from
soils (Kierski, 1992; Mushak, 1998) suggest that bolus administration of a large mass of metal
and/or metal-containing soil matrix may be associated with a lesser degree of gastrointestinal
absorption, in terms of percent of total ingested amount, than might result from administration of
the same mass in smaller, divided doses.
Members of the Panel expressed concern that the findings of Roberts et al. (2001) and Freeman
et al. (1995) have not provided a sufficient basis to establish a relative bioavailability of 25% for
arsenic present in soil as a consequence of CCA related release or contamination. The single,
high dose, bolus administration of arsenate and arsenic-containing soils used in the studies by
Roberts et al. (2001) and Freeman et al. (1995) does not reasonably simulate the relatively low
dose, repeated ingestion of arsenic-containing soil that would be anticipated with hand-to-mouth
behavior of a child playing in the vicinity of a CCA application. The arsenic concentration of the
test soils (ranging from 101 to 743 mg/kg) appears high relative to those measured in the vicinity
of CCA-treated structures in children’s playgrounds in several recent investigations. The
experimental design used by the investigators resulted in these soils being introduced into the
monkey test subjects in single high mass boluses. For example, in the case of soil obtained from
a “wood treatment site”, it may be calculated that the soil-associated arsenic dose of 0.3 mg
As/kg body weight was achieved by administering a 3 kg monkey a single oral dose of 9000 mg
of soil. In like manner, in Freeman et al. (1995), the monkeys (which weighed between 2 to 3 kg)
18
were given single, oral doses of 3000 to 4500 mg of soil containing 410 ppm arsenic. Enhanced
confidence in the generalizability of the relative bioavailability values from such studies might
be obtained from experimental designs that utilize multiple, smaller soil doses spanning a range
of relevant arsenic concentrations.
There is uncertainty regarding the extent to which the test soils used in the studies by Roberts et
al. (2001) and Freeman et al. (1995) reflect arsenic speciation and chemical and physical
characteristics of the soil matrix in the vicinity of CCA contamination at a playground.
Although a soil sample from the investigation by Roberts et al (2001) was identified as coming
from a “wood treatment site,” this sample was not characterized further. The arsenic in that soil
may have resulted in part from direct spillage of raw CCA product onto the soil, rather than
leaching of arsenic from a weathered piece of CCA-treated wood.
The animal model used in the studies by Roberts et al. (2001) and Freeman et al. (1995) were the
Cebus apella monkey and the cynomolgus monkey, respectively. Intravenous dosing with
sodium arsenate suggested that these nonhuman primates were similar to humans with respect to
excreting absorbed arsenic almost entirely through the urine (<5% of the recovered dose
occurred in the feces). Also, the extent of excretion of an oral dose of sodium arsenate in urine
and feces was quite similar between these monkeys and humans. At this point in time, the Panel
is not aware of information regarding the biomethylation patterns of arsenic species in these
nonhuman primates. This is an issue of some concern for some Panel members because other
nonhuman primates, such as the marmoset monkey, do not biomethylate arsenic and exhibit
prolonged retention of some arsenic species in vivo. These Panel members thought that this
could potentially result in an underestimation of relative bioavailability if a significant
proportion of the arsenic specie(s) present in the test soils was retained in the body for a longer
period of time relative to the reference material, sodium arsenate in solution. Underestimation
could also result if arsenic present in the test soil underwent greater relative biliary excretion
compared to sodium arsenate. Other Panel members acknowledged these possibilities but
expressed the opinion that these factors were not likely to significantly affect the findings.
At the present time, little is known regarding differential absorption and metabolism of arsenic in
juvenile versus adult animals. Some Panel members expressed concern that the developmental
age of the animal model might be a potentially significant variable, since it is known that infants
and even older children as well as very young animals, sometimes have the potential for
increased uptake of contaminants. Although the swine models have utilized juvenile pigs, the
current monkey bioavailability data were obtained with adult animals. To the extent that the
nutritional or dietary status of children and experimental test animals may affect the uptake of
other substances, the absorption of arsenic (particularly arsenate) in the face of phosphorous
deficiency is of potential concern for these Panel members. They noted, for example, that
arsenate uptake by cells has been shown to be increased in low phosphate media (Huang and
Lee, 1996) and suggested the need for further research on the impact of nutritional and
developmental factors on bioavailability determinations. Other Panel members pointed out that
the absorption of arsenite and arsenate, in absolute terms, is already extensive in adult animals
and humans. As a result, the potential for greater absorption in children is limited, and
consequently they did not think that use of arsenic bioavailabilty values from adult animals was
19
a significant concern (the Panel members thought that arsenic bioavailability values from adult
animals were applicable to immature subjects).
As discussed in more detail elsewhere in this report, the interactive effect of metal combinations
may influence arsenic absorption, biotransformation, and excretion. For example, when
administered together with selenite, some inorganic arsenic compounds undergo increased
biliary excretion (Levander, 1977; Gailer et al., 2000) , a factor that may potentially serve to
underestimate relative bioavailability in models that examine relative urinary excretion as a
marker of relative bioavailability.
Panel members noted several other studies that have investigated the oral bioavailability of
arsenic in soils. Widely divergent results for relative bioavailability have been reported, a finding
that is not unexpected given the variability in soil-associated arsenic compounds, soil matrices,
animal models, and experimental design. For example, Casteel et al. (2001), under the auspices
of U.S. EPA Region VIII, recently examined the relative bioavailability of arsenic in soils from
the VBI70 superfund site in Denver, CO. Using a swine model that investigated six soil
specimens spanning a range of arsenic concentrations, the mean relative bioavailability was
31%, with a 95% upper confidence limit of 42%. This latter value (42%) has been utilized in risk
calculations contained in the site’s baseline risk assessment (US EPA, 2001). Other relative
bioavailability studies have been noted or reviewed in the Inorganic Arsenic Report of the
Hazard Identification Assessment Review Committee (HIARC, 8/21/2001), and a recent
publication by Ruby et al. (1999). Results for relative bioavailability have ranged from near zero
to 50%, with the exception of two soils from Aspen, CO, that yielded much higher results, albeit
with extremely wide confidence intervals (62% ± 55, 98% ± 86; Casteel et al., 1997; Ruby et al.,
1999).
Question 3:
Please comment on the selection of the value of 6.4% for dermal absorption
of inorganic arsenic and whether or not this value will be appropriate for use
in all scenarios involving dermal exposure to arsenic from CCA-treated
wood, including children’s dermal contact with wood surface residues and
contaminated soils.
Recommendations
The Panel recommends that EPA use a value less than 6.4%, probably in the range 2-3%, for
dermal absorption of inorganic arsenic. The Agency should consider using a figure for
absorption rate (e.g., percent exposure absorbed per hour) rather than a value for percent
absorption.
Research, using arsenic in more appropriate chemical form (that it is present in dislodgeable
CCA residues and in soil beneath CCA-treated sites) and in a relevant matrix, should be carried
out to improve estimates of dermal absorption.
20
Discussion
The Panel accepted the EPA view that the publication by Wester et al. (1993) provided the most
appropriate available data for addressing this question. This research included a study that used
seven rhesus monkeys. The absorptions of the pentavalent arsenic species H 3AsO4, radiolabeled
with As73, in water solution and added to soil, were compared. For both water and soil, a highexposure and a low-exposure group were used. The low exposure groups represented “the
minimum arsenic that could be used given the specific activity of the compound.” These
exposures were 0.00004 µg/cm 2 for the soil group and 0.000024 µg/cm 2 for the water formulation
group. The high exposure group was described as “representative of what would be encountered
in more contaminated areas.” These exposures were 0.6 µg/cm 2 for the soil exposure group and
2.1 µg/cm 2 for the water group. The skin exposures were for 24 hours and confined within a
non-occlusive cover. Urine was collected for seven days following the beginning of the
exposure period. Results were adjusted for excretion by other routes than urine and for retention
in the body using results from monkeys that had been treated with an intravenous dose of
arsenic. The data showed that 80.1% of the intravenous dose administered to the monkeys was
excreted in the urine over a period of seven days.
The Panel noted a number of limitations in the reporting of the design and conduct of the study
by Wester et al. These included:
•
Uncertainty whether separate monkeys had been used for the dose groups or the same
monkeys had been reused. If the latter, then it raised the possibility of crosscontamination, such that there could have been continued “slow leaking” of arsenic from
body reservoirs that would have affected latter parts of the experiment.
•
The large particle size of the soil used. Particle size is likely to affect bioavailability
because of differences in surface-to-volume ratio.
•
The procedure by which arsenic was added to the soil was not described. The contact
period prior to skin application appears likely to have been very short relative to the time
that would be necessary for binding to the soil particles.
•
The water in which the arsenic was dissolved was not adequately described in terms of its
chemical characterization.
•
There was no information on whether the cage was washed to collect radioactivity and, if
so, how this was taken into account for the purposes of calculating the absorbed dose.
•
To keep the soil on the skin, a device made of two aluminum eyeguards sandwiched
around a Goretex membrane was taped over the soil after application to the skin. The
soil used had a particle size distribution larger than would typically be expected to adhere
to skin. It is likely that soil fell to the bottom of the dosing device (which had a larger
volume than the volume of the soil applied) and was not uniformly distributed on skin.
21
•
The applicability of soil and water data to arsenic residues derived from wood surfaces is
unknown.
Results of the study by Wester et al. (1993) were as shown in the following table:
In vivo percutaneous absorption of arsenic from water and soil on Rhesus Monkeys
Percent applied dose
Low exposure
6.4 ± 3.9
Water
High exposure
2.0 ± 1.2
Low exposure
4.5 ± 3.2
Soil
High exposure
3.2 ± 1.9
An inverse relationship between exposure concentrations and percent absorbed was noted. The
lowest exposure (water formulation) was associated with the highest percent absorbed – 6.4%.
This value was proposed by EPA as the default value for skin absorption.
The Panel considered that, on general toxicological principles, for the purpose of extrapolating
the results to humans, it would be more appropriate to have results obtained using a more
realistic level of exposure, namely the higher exposure level used in the experiment. In that
regard, it was also noted that the soil group had a higher degree of arsenic absorption (3.2%)
than the water formulation group (2.0%). There were two possible reasons why this might have
happened: 1) a factor in the soil that promoted exposure or 2) random biological variation
because of the small numbers of monkeys in the groups (three monkeys in the water formulation
group and four in the soil group). The Panel considered the second reason the more likely.
On this basis, the Panel considered that a value for skin absorption in the range 2-3% would be
more appropriate than 6.4%. However, it was felt that this was likely to overestimate actual
absorption, because the monkeys had been exposed for 24 hours and the form of arsenic used in
the experiment was probably more water soluble than arsenic from CCA treatment. Also, the
treated soil had had no opportunity to “age,” a process that could bind the arsenical molecules
more tightly to the soil matrix and reduce absorption. The possibility of considering a measure
of absorption that took into account time of exposure (i.e., absorption rate) was felt to be worthy
of further consideration.
A separate in vitro experiment reported by Wester et al. involved measuring absorption of
arsenic from water and soil on human skin. This gave a result of 0.76 % absorption from soil
and 1.9 % from water.
It was also noted that there was a lack of information on the chemical form of arsenic in CCA
residues. The assumption was that residues were likely to be in the pentavalent form. If there
were trivalent arsenic present, then the kinetics of arsenic absorption could be different.
However, there is no available information on skin absorption of trivalent arsenic compounds.
22
In view of the limitations of the research on which this evaluation was based, the Panel
considered that there was an urgent need for further research on skin absorption of CCA
residues, employing the form of arsenic found in dislodgeable residues and soil from CCAtreated installations.
The Panel also considered a proposal by two of the public presenters – Gradient and E xponent –
to adjust the percent absorbed (as determined by Wester et al.) by a factor representing the
relative bioavailability of gastrointestinal absorption of CCA arsenic residues. The rationale for
this adjustment was that the Wester experiment had used a more water soluble form of arsenic
than was present in CCA residues, and it had not had the opportunity to “age” after being added
to soil. The Panel accepted that the form of arsenic used in the experiments by Wester et al.
(1993) was not ideal, but considered it inappropriate to adopt this proposal for an adjustment
factor, since it would involve a form of “double-counting” of soil-related factors that reduce
absorption. It was felt that the recommended research would better address the issue identified
by Gradient and E xponent.
Question 4:
As available monitoring data do not differentiate among chromium species
found in CCA dislodgeable residues on wood surfaces and in soils, and as Cr
(VI) is the more toxic species of chromium, please comment on whether use
of the hazard data for chromium (VI) is the best choice for characterizing
hazard and risk from exposure to chromium as a component of CCA-treated
wood. Please provide a scientific explanation and justification for your
recommendation on the choice of either the chromium (III) or chromium
(VI) hazard database.
Recommendation
It is the Panel’s conclusion that, at present, there is no reliable evidence on either the presence or
absence of Cr(VI) in dislodgeable residues on treated wood surfaces. Some measurable Cr(VI)
probably exists in certain soils, but it is unlikely to be 100% of total chromium. One approach
would be to use an estimate of 25 to 50% hexavalent chromium. Some Panel members
suggested 5 to 10% would be conservative. In order to be health protective, it would be
scientifically reasonable to use the Cr(VI) hazard database with respect to a range of chromium
fractions. The Panel strongly recommends that EPA conduct studies of chromium speciation (in
both dislodgeable residues and soil samples) in their proposed studies.
Discussion
There was little disagreement that available information on the valence state of chromium did
not establish either the presence or absence of Cr(VI) in dislodgeable residues. The speciation
data presented at this meeting are limited. However, the limited Florida data suggest that Cr(VI)
may not be a major environmental hazard, even as we acknowledge that the hexavalent form of
chromium is the more significant health hazard. Further research on valence speciation of
chromium at sites where treated wood is being used is warranted.
23
Several members of the Panel noted that detection of Cr(VI) would be confounded by the fact
that Cr(VI) in dislodgeable residues would be much more soluble and therefore more mobile to
transport off treated surfaces with rain events. This complication could be accounted for in the
future pilot studies being planned by EPA and CPSC. The Panel did not elaborate further on the
issue of Cr(VI) in dislodgeable residues, and the rest of the Panel’s focus was on valency issues
for soil chromium.
Several members of the Panel noted that there is some evidence from two types of studies that
Cr(VI) can exist in soils in measurable amounts. The fraction of Cr(VI) in soils is highly
dependent on such soil characteristics as moisture content, pH, binding sites for adsorption on
mineral and organic components, etc. One line of study entailed experimental evaluation of
Cr(VI) formation and stability in soils of differing chemical, moisture, and complexing types
(Bartlett, 1991; Bartlett et al., 1983; Bartlett et al., 1979).
A critical factor in formation of Cr(VI) in undisturbed, non-acid soils of typical moisture content
is the oxidation of Cr(III) to Cr(VI) by manganese oxide. Bartlett also reported that Cr(VI) can
be adsorbed and stabilized to some extent.
A second body of information consists of determination of the fraction of Cr(VI) in soils in
Hudson County, NJ, which received alkaline chromite ore processing residues. The fraction of
Cr(VI) ranged from 1-50% (Burke et al., 1991). At this site, the amount of Cr(VI) was seldom
more than 10%. In situations where the chromium was in solution in surface water, chromium
blooms (crystallization) occurred on the soil surface as the soil dried out and contained up to
50% Cr(VI).
The overall discussion by the Panel of what fraction of Cr(VI) in soils should be adopted by EPA
in any preliminary risk assessment efforts elicited a range of values and a variety of conclusions
as to their significance. This variety of opinions included a desire to wait for the pilot studies
being planned nationally before going any further. Some members indicated a range from 510% would be conservative. Other Panel members indicated a range of 25 to 50%. One Panel
member noted that it was inappropriate to consider the chromite ore residue data in New Jersey.
It was generally the view that it would be unlikely that 100% of total chromium would be
present as Cr(VI) in playground and deck areas. Conversely, no Panel member tendered the
view that Cr(VI) would never exist in any soils associated with playgrounds and/or decks
constructed of CCA-treated wood.
The Panel generally was interested in having the planned studies by EPA and CPSC include as
much chemical speciation data as possible -- much more than the agencies had indicated in their
draft protocols.
One Panel member, with assent from others, noted that the issue of chromium valency in soils is
not subordinated to the subsequent redox transformations that might be assumed to occur in the
stomachs of children ingesting soils containing Cr(VI). That is, any transformation of Cr(VI) to
Cr(III) in receiving body compartments (lung, GI tract) occurs via uptake of Cr(VI) and
24
formation of intermediate, bioreactive valencies that may be linked to the mechanism of the
toxicity of Cr(VI).
Question 5:
Please comment on the Agency’s selection of the 0.5 mg/kg/day NOAEL
value for use in assessing risks to the general population as well as children
from short-term and intermediate-term incidental oral exposures to
inorganic chromium as contained in CCA-treated wood. Please provide an
explanation and scientific justification for your conclusions as to whether the
presented data are adequate or whether other data should be considered for
selection of these endpoints.
Recommendation
The Panel expressed concerns regarding the selection of the 0.5 mg/kg/day NOAEL for shortterm and intermediate-term incidental oral exposures to inorganic chromium. In general, these
concerns involved the appropriateness of the study selected by EPA (Tyl, 1991) to derive this
value. It is the Panel’s recommendation that the Agency re-review the literature and consider
other potentially more relevant studies.
Discussion
The SAP agreed that the most appropriate toxicology data for the development of the NOAEL
should involve the same species of chromium as present in CCA-dislodgeable materials and
contaminated soils which are the subject of the risk assessment. Given the absence of
appropriate data, this decision will ultimately depend on the results of field studies such as the
playground studies proposed by EPA/CPSC.
The Panel questioned whether the study proposed for the derivation of the NOAEL (Tyl, 1991)
actually demonstrated the purported effect. The Panel was divided on this issue; some thought
the study adequate and appropriate to support the proposed NOAEL while others thought the
study to be flawed and inappropriate.
•
The selected study had the primary purpose of evaluating the reproductive and
developmental effects of exposure to Cr(VI). While no developmental effects were
observed, maternal effects were noted and were used to derive the NOAEL. Rabbits
were given a bolus of chromic acid (CrO 3) diluted in distilled water by gavage for twelve
consecutive days. Dosing was at 0, 0.1, 0.5, 2.0, 5.0 mg/kg/day levels; the 5.0 mg/kg/day
dose was noted to have a pH of 1.52. Maternal effects observed included mortality in the
2.0 and 5.0 mg/kg/day groups and reduced weight gain, decreased food absorption
efficiency, labored breathing, and diarrhea in the 5.0 mg/kg/day group. No pathologic
abnormalities were noted in any group.
Several members of the Panel questioned the attribution of the observed effects to the Cr( VI)
dosing; they believed that an acid effect could not be ruled out. Others discounted this
possibility stating that dietary residues could readily neutralize the acid. Specifically, it was
noted that rabbits retain half their ingested diet 24 hours after conventional fasting began
25
(Carmichael et al., 1945) and this residue would serve to buffer against acid injury from acidic
media given after conventional fasting. There was no resolution of this difference in
interpretation.
Studies cited by the Agency (MacKenzie, 1958) and Zhang and Li (1987) are generally
supportive of the NOAEL value derived from Tyl, but, as noted by OPP, these studies suffer
from a lack of definitive exposure information and are of inappropriate duration for use in
deriving a short or intermediate measure.
Question 6:
Please comment on whether the significant non-systemic dermal effects from
dermal exposure to inorganic chromium should form the basis of dermal
residential risk assessments, and, if so, how the Agency should establish a
dermal endpoint for such an assessment.
Recommendation
The Panel advises that EPA should base risk assessments for noncancer health effects of dermal
exposure to hexavalent chromium on direct dermal effects – irritant and allergic contact
dermatitis. The Panel was unable to provide EPA with methods for establishing endpoints and
determining dose response relationships for these effects.
Discussion
It is unlikely that sufficient chromium could penetrate the skin and enter the circulation to cause
systemic effects from dermal exposure. Skin penetration for chromium is estimated to be 1%. It
is usually assumed that the contribution to systemic effects from dermal exposure is not likely to
be significant relative to oral exposure. Direct dermal effects (irritation and allergenicity) are
therefore likely to be the controlling endpoints as far as dermal exposures are concerned. The
Panel therefore advises that EPA base its residential risk assessments for the dermal route on
these direct dermal effects. In order to make sure this route is inconsequential for systemic
effects, one could run a PBPK model and compare the target tissue doses from the oral and
dermal routes.
The Panel believes that EPA should consult with the New Jersey Department of Environmental
Protection (see Bagdon and Hazen, 1991) concerning establishing dermal endpoints and
performing dose response assessments for dermal exposure to chromium using direct skin effect
endpoints. The main problem will be determining the appropriate endpoint and obtaining a
usable dose estimate from the published literature using data from exposure of workers and other
exposed individuals (Bagdon and Hazen, 1991; Burke et al., 1991) or possibly from animal
experiments mentioned in the ATSDR document (Mor et al., 1988; Gross et al., 1968; Jansen
and Berrens, 1968).
Question 7.
Please comment on whether OPP’s choices of central tendency and high end
values for different parameters should, collectively, produce estimates of the
middle and high end of the range of potential exposures. If the Panel thinks
that OPP’s approach may not estimate the high ends of the exposure range
26
(because it produces values that are either higher or lower than the upper
end of the exposure range), please comment on what specific values should be
modified to produce estimates of the high end of potential exposure.
Recommendation
The Panel offers the following recommendations:
• Particularly when using point estimates it is important to do subset analyses for specific
regions of the country (for example, the South compared to the North or Midwest) and
for age groups (for example, one year olds compared to 5-6 year olds).
• The averaging of exposure over a 75-year lifetime may underestimate risk. More research
is needed to understand the uncertainty associated with this form of temporal averaging.
• More research is needed on the amount of soil ingested, as this is still a source of
uncertainty.
• For fully evaluating high end exposures it would be necessary to include exposure of
children with Pica.
• A probabilistic assessment as discussed in question 8 is recommended.
Discussion
Comments of OPP’s choices of central tendency and high-end values for different parameters
have been approached in two ways: assessing the quality of the specific values OPP has
presented and evaluating whether the point estimates used in the Agency’s calculations will
provide reasonable estimates of the high-end exposure range.
Specific values
The prototypical three year old behaviorally does not represent either a one year old or a six year
old. In addition, the surface area used for fingers, 20 cm 2, while appropriate for a three year old,
would be an overestimate for young children, since both the surface area of the hand and the
proportion of the surface area which is fingers are different for younger children. This is an
argument for either doing subset analyses for smaller age groups, or doing probabilistic
evaluations.
Time spent at play outdoors may be an overestimate for the measure of central tendency. Both
NHAPS data and that reported by Silvers et al. (1994) suggest that most of the time children are
at play outdoors is on grass or paved areas, neither of which represent the types of substrates
typically found around CCA wood play structures.
The assumption that the average child spends 130 days playing on these structures is also not a
realistic central tendency measure. The National Human Activity Pattern Survey (NHAPS) data
for children 1-4 years old suggests that on any day only 50% of children may play outdoors and
that, of those, approximately 40% would play on the types of substrates on which play
equipment is found. Data presented from Florida suggest that there may be major regional
differences in these estimates which would not be treated well with point estimates unless
regional subset analyses were done.
27
The hand to mouth frequencies proposed are based on both indoor and outdoor mouthing
periods. Freeman et al. (2001) found that, among children in Minnesota, mouthing rates were
significantly higher indoors than outdoors (approximately 3 times higher indoors). At the same
time, if residues or soil adheres to hands, the ingestion of that material may not take place
outdoors, but occur indoors after the child has played on the equipment. Freeman in her own
evaluations has shifted to using the median value of Reed’s data (8.5/hr) rather than using the
mean of 9.5/hr as a more conservative value for a measure of central tendency. It should be
noted that most mouthing behaviors occur indoors during quiet times such as when watching
TV. It has been infrequently observed during active outdoor play other than by infants and very
young toddlers.
The issue of whether replenishment occurs after mouthing needs to be addressed. Contacts with
surfaces and objects are “fast and furious,” with the average contact duration of 4 seconds and
hundreds occurring per hour. If total replenishment occurs after 4-5 contacts (Rodes et al.,
2001), then it is likely that the fingers are fully loaded between mouthing events.
Some Panel members noted that the central value for soil ingestion rates of 100 mg/day is
probably an overestimate. Median values reported by both Stanek and Calabrese (1995), and
Davis (1990) range from 0-96 and 25-81 mg/day, depending of the tracer used. Other estimates
range between 35-70 mg/day and may be more realistic (Sedman, 1989 and 1994; Calabrese,
1995). These values also represent total soil consumption for the day, and not just from the 1-3
hours of play by CCA treated equipment, which would be something less than 100% of daily soil
consumption. In addition, the use of 400 mg/day as the high-end value is also an overestimate
based on Calabrese and Stanek’s work.
In considering high-end exposures, the Agency might consider including an evaluation of
children with Pica behaviors. This is an area for which there are little data but may be important
for understanding the high end exposures.
Reasonable estimates
The dermal and ingestion models proposed are very simplistic, but there is no harm with trying
them and trying a variety of inputs as a first step in understanding exposure and risk. There may
be no point trying to agree on a correct set of inputs at this time. Additional data on dermal and
ingestion exposure will improve the models and reduce uncertainties. All of the coefficients and
parameters seem to be conservatively biased toward overestimating exposure. When inflated
“central tendency” values are put into the deterministic exposure calculation, they can be
expected to overestimate the expected or “central tendency” exposure. If the distribution of
exposure is highly positively skewed, this bias may be considerable. In some cases the arithmetic
mean values presented are substantially skewed and should be replaced by median values as a
better indicator of central tendency.
Working with the high-end values will be even worse, as the result will correspond to the very
rare event of an exposure that is extreme in every aspect and hence will be higher than is ever
observed in reality.
28
Looking at the general variables that the Agency proposes to use for characterizing child
exposures through dermal and oral routes, the general conclusion is that using a range of values
in a probabilistic evaluation should be the way to approach evaluating child exposures. Issues
related to a probabilistic model are discussed in Question 8.
If the deterministic model is used, any parameters that are unnecessarily inflated should be
reduced. One value to look at first is the calculation of skin surface area, which could be
replaced by the “effective skin surface area.” The hours per day of playground activity could
also be looked at, the days per year will probably vary regionally.
The models proposed by the Agency for the study of children's acute and chronic CCA metals
exposures (ADD-average daily dose and LADD-lifetime average daily dose) from play
structures involve the composition (through multiplication and division) of stochastic variables
from multiple sources and transitions in the dermal and oral exposure routes. The true
composite exposure distribution is expected to be right skewed (e.g., log normal or similar
distribution). It is also expected that the distribution is left censored—rarely at zero
exposure—but at other exposures not related to playground or play structure use.
Estimates of ADD and LADD distributions, their means, medians, and quantiles, should reflect
the distributional parameters (means and variability) of each of the exposure components, the
covariance of the exposure components, and, through sensitivity analysis, the uncertainty
(variance and bias) of the sample-based or postulated value of these parameters. In addition, the
influence of covariates (e.g., region, climate) not explicitly included in the estimation model
must be taken into account.
The proposed estimators of ADD and LADD are simple product and/or ratio statistics. In the
simple case of a product of two variables, the product of central tendency values is
E(X) E(Y) = E(XY) – Cov(X, Y)
This implies that for positively correlated X, Y the product of means will underestimate the
mean of the product.
Furthermore, if these central tendency measures are estimated from sample data, the
approximate variance of the product is
Var(X Y) = Var(X) E2(Y) + Var(Y) E2(X) + 2 Cov(X, Y) E(X) E(Y)
That is, the variance of the product will be inflated if there is a positive correlation between the
variables. For statistics such as the proposed estimators of the ADD or LADD, the properties
illustrated here for means of two distributions will be propagated through calculations involving
means of more than two variables.
The median of the product X Y may not be the product of the median even if the two
distributions are uncorrelated. To illustrate, take two simple discrete uniform distributions, X=(1,
29
2, 3), Y = (2, 8, 14). Generate all possible (X, Y) pairs and create the distribution of their product
(e.g., 1 x 2=2, 1 x 8 = 8, etc.) assuming no correlation. The composite product distribution
includes 9 equally likely values X Y=(2, 4, 6, 8, 14, 16, 24, 28, 42) with median = 14, but the
product of the medians of the X and Y distributions is 2 x 8 =16.
Likewise, the product of the medians and other distributional quantiles (e.g., Q 90, Q95) for X and
Y that are positively or negatively correlated will be biased for the quantile of their product
distribution. The direction and magnitude of the bias will depend on the size of the correlation
and the shape (symmetry and variability about mean) of the distributions of X and Y. The
theory here is based on Dirichlet distributions for the products of order statistics.
The alternative to the deterministic approach that is proposed is a probabilistic modeling of the
exposure routes. Bayesian methods, possibly with flat priors over the range of measured
parameter values, might be considered as the probabilistic approach is developed.
Question 8:
Please comment on whether the existing data bases on the variability of the
different parameters affecting potential exposure are adequate to support
the development of probabilistic estimates of potential exposure. If the Panel
regards the data bases as adequate for that purpose, please identify which
parameters should be addressed using a distribution of values and which
data bases should be used to supply the distribution for particular
parameters.
Recommendation
In view of its concerns that the deterministic model reviewed in Question 7 will not correctly
estimate the central tendency or percentiles of the exposure distribution, the SAP recommends
that the EPA immediately begin to take steps toward the development and progressive
refinement of probabilistic models of exposure. The probabilistic models will give high-end
values that are interpretable as a percentile of the modeled exposure distribution rather than a
biased approximation of the upper limit of exposure. The existing databases on the variability
of the different parameters affecting potential exposures of children using CCA-treated
playground structures are adequate to begin the development of probabilistic estimates of
potential exposure provided the uncertainty associated with these data is reflected in the
exposure modeling. As noted above, the Panel views the development of a probabilistic
assessment as a process of progressive learning and refinement. New or more detailed data on
states and transition factors are needed and will contribute to improvements in the exposure
models as they become available.
Discussion
The Monte Carlo risk assessment of CCA metals exposures presented by the Environmental
Working Group (EWG), while it contains several deterministic and simplifying assumptions, is a
good start and illustrates what can be done with existing data. The use of a probabilistic
approach avoids the arbitrariness and artificiality of selecting single values to represent factors
that are known to vary considerably across individual exposures. This advantage is of particular
30
importance for the case of the RME estimates, where it has been demonstrated that the selection
of reasonable upper bounds for several distributed parameters used as independent variables in a
calculation can result in an estimate of the dependent variable (e.g., exposure) that is
unreasonably far out in the tail of the probability distribution for that variable.
EPA guidelines for probabilistic exposure assessment and software programs like SHED, ReX,
LifeLine, and Calendex can be used to perform a multi-dimensional analysis (separating, to the
extent possible, variability and uncertainty). The LifeLine and Calendex models that have been
reviewed by prior SAPs and proposed for studies of cumulative (including residential) exposure
to organophosphates provide basic algorithms for beginning probabilistic approaches. One
advantage of these programs is that they permit inspection of individual exposure values and the
cumulative contribution of individual components to aggregate exposures. In these software
systems, varying degrees of deterministic analysis can be forced by simply limiting the
variability of the stochastic distributions.
The Panel recognizes that probabilistic exposure assessment is a relatively recent advance in risk
assessment methodology. Therefore, a parallel approach is suggested, in which deterministic
exposure estimates may be determined quickly and in advance of probabilistic estimates
primarily to develop an initial understanding of which parameters have the greatest leverage on
the final distribution of exposure outcomes. In addition, it is recommended that a limited
variability analysis, similar to that presented by EWG, be performed as well as a full
variability/uncertainty analysis. If a probabilistic approach is used, the 50 th and appropriate
upper percentiles can be used as the central tendency and high-end estimates, respectively. Even
if the Agency determines that a probabilistic approach cannot be used for the exposure estimates,
the probabilistic results will play an important role in the risk characterization, for characterizing
the variability of individual risk, the impact of uncertainty on the risk estimates, and the
suitability of the selected central tendency and “high-end” values used in the deterministic
calculations.
As mentioned above, a limited variability analysis could be performed in a similar fashion to the
analysis presented by EWG. In this case, the Monte Carlo analysis would only vary parameters
for which substantial data on variability are available. In the EWG analysis these included daily
soil ingestion, dislodgeable arsenic, soil arsenic, and body weight. The approach used by EWG
for body weight and surface area, following a child from 12 to 84 months of age with the
opportunity for moving, is recommended, since it permits the incorporation of other agedependent parameters such as mouthing behavior.
The details of the Monte Carlo analysis will need to be determined by considering the presumed
nature of the anticipated exposures and the available data. For example, if it is assumed that a
child uses a single playset for the entire 6 years, then a single randomly selected data set for
dislodgeable arsenic can be associated with each child. If it is assumed that a child would use
more than one playset, a more complicated sampling approach would be necessary.
Alternatively, a very simple approach would be to repeatedly select at random from the totality
of the data for dislodgeable and soil arsenic and use these selected values in the deterministic
formulas together with the assumed values for the other parameters. The Panel encourages the
31
Agency to plan for modeling the exposure risks not only of special scenarios of individual
exposures but also exposures in special high-risk populations. Such high-risk populations might
include children in day care settings and living in warm climates, where the exposures to CCA
treated wood may be more frequent and of longer duration than in the general population at
large.
The more complete two-dimensional analysis should include distributions for all of the
parameters in the exposure calculations. To the extent possible, separate distributions would be
developed to describe variability (inherent variation) and uncertainty (lack of certainty regarding
the correct value). The resulting exposure estimates would take the form of a “distribution of
distributions” in which the variability around the central estimate would be displayed in one
dimension while the uncertainty in the central estimate would be displayed in the second
dimension. The multiple curves presented by EWG for different parameter assumptions is a
(simpler) example of such a concept. However, instead of just showing the variability results for
discrete alternatives of the uncertain parameters, distributions would be presented. The
distributions used to describe uncertainty are necessarily much simpler than those informed by
variability data. For example, a parameter may be characterized as having a uniform distribution
(with equal likelihood of being anywhere in a given range), or by a triangular distribution (with a
peak at the best estimate and vertices at the extreme values). The biggest problem with this
approach is that there is often considerable uncertainty whether the observed differences in the
value of a parameter represent variability or uncertainty or variability compounded by
experimental bias (which introduces uncertainty). It is usually valuable to perform an analysis
on the probabilistic approach that evaluates the sensitivity of the conclusions to alternative
decisions that could be made regarding the variability/uncertainty distributions. As mentioned
earlier, even if it is decided that the use of such an analysis for the risk assessment would not be
appropriate, the results of the analysis would be very useful for characterizing the potential
impact of uncertainty on a risk assessment using a partial probabilistic/deterministic approach.
Publications and presentations given to the Panel indicate that more data are needed to
characterize other sources of variation and that there are more factors that need to be included in
the model.
One area of improvement that could be addressed immediately is better representation of agespecific differences in children’s body size and behaviors. For modeling population exposures, a
first improvement over the current assumption of a fixed age and body weight for exposed
children is to draw on data for children that are available from major survey data sets such as the
National Health and Nutrition Examination Survey (NHANES). The EWG simulation study
presented to the SAP by Dr. Houlihan used this approach. These samples of children provide
representative age- and gender-specific data on body weights and heights for U.S. children.
Modeling of exposure should adopt the methodology employed in LifeLine and other software
that “ages” the child through the exposure window. As the child ages in the probabilistic
simulation, the appropriate age-specific activity and exposure factor data are applied to estimate
time-dependent contributions to short- and long-term exposures.
Another major source of uncertainty in the current model of exposure is the data on the
32
distribution of frequency and duration of children’s exposures to CCA-treated wood play
structures. The deterministic model proposed in the EPA presentation to the SAP makes a very
simplifying assumption of constant daily and annual exposure frequency for six years of life.
Obtaining precise, nationally representative time and activity data for children in the relevant age
ranges would be tremendously costly. However, small local studies and existing small-sample
data from the National Human Activity Pattern Survey (NHAPS), the Child Supplement to the
Panel Study of Income Dynamics (PSID; http://www.isr.umich.edu/src/childdevelopment/publications.html ), and other studies could be used to better approximate the
variability in frequency and duration of outdoor play. These data could then be interpolated to
approximate time spent on CCA-treated play structures. We need more detailed information on
the relative time spent on the structure and in the substrate. These data might be obtained from
existing or new observational studies. Activity patterns will very likely depend on the weather,
as children may, for example, avoid sand that is too hot or too wet. Data on the correlation
between As/Cr in the structure and its substrate will be needed to use this information.
The EPA is planning a new survey of existing playground structures and substrates. These
should be executed as one combined survey to look for correlations between existing structures
and their substrate. All possible covariates should be recorded in the hope that the “unexplained
variation” in As and Cr levels could be reduced from what we have seen in studies to date.
Covariates might include the following: evidence of construction debris (sawdust) in the
substrate, nature of substrate (clay, sand, etc.), source of wood, age of structure, condition of
surface (new, aged, worn to a shine), climate. Initially, the probabilistic modeling could rely on
the empirical distributions provided by Townsend, et al. and Stillwell data on soil and surface
residue concentrations. The Panel expects that the new survey data will be substituted when they
become available. In its response to Question 11, the Panel recommends that data obtained in
studies of CCA treated decks not be viewed as representative of dislodgeable residues on CCA
treated play structures or in the soils or substrates beneath these structures.
Panel members also identified the transfers of CCA residues from surfaces and soils as a major
uncertainty factor in the modeling of exposure. For example, it is possible that wet-weather play
and play on damp structures bring increased risk of uptake, but there seems to be no information
other than wet-hand/dry-hand wipe studies. The Panel strongly recommends that the EPA
explore and evaluate alternatives (by comparison) to the hand loading transfer efficiency in
modeling the transfer of CCA metals from surfaces and soils to the child’s hands and other skin
surfaces. Specifically, the Panel recommends that the EPA conduct direct hand loading
measurements in samples of children (preferably) or adults (if human subjects concerns
intervene). The best empirical data may actually be collected through sampling of children who
are actively involved in playing on CCA treated structures. The Panel also cautions that
empirical distributions of arsenic and chromium concentrations measured in these hand loading
studies not be used as the concentration values for dermal exposure through non-hand skin
surfaces. One Panel member noted that probabilistic exposure models should allow occasional
events like splinters and abraded skin to be included in the exposure pathway.
The Panel also noted that the better distributional data on children’s outdoor hand-to-mouth
frequency and the fraction of residue transfer are needed to improve the probabilistic modeling
33
of children’s exposure. Data from Dr. Natalie Freeman and her colleagues is expected in the
Spring of 2002. Preliminary results will be presented at a conference in early November, 2001.
In its response to Question 8, some Panel members noted that there ultimately should be a
biomonitoring study that does a reality check on the predictions of the model, perhaps arranging
a sample of children to play in a CCA-free environment for several months and comparing some
measure of arsenic uptake with the same measure in a matched sample using existing CCAtreated playgrounds. The suggestion was made to collect urine samples from children during the
time period after they had actively played on treated and untreated structures. A further
comment was made that any analysis of arsenic in urine should examine the speciation of the
arsenic. The topic of biomonitoring studies was discussed at length at the conclusion of the
question responses. The reader is referred to the general summary of this discussion for a
summary of the Panel’s recommendations on the need and design issues for biomonitoring
studies.
Question 9:
OPP is assuming that a one-to-one relationship applies to the transfer of
residues from wood to skin. The Panel is asked to address whether this is a
reasonable assumption, and if not, to provide guidance on other approaches.
Recommendation
The Panel does not recommend assuming that a one-to-one relationship applies to the transfer of
CCA chemical residues from wood to skin as proposed by the Agency. It is the Panel’s opinion
that the underlying conceptual model is questionable. Sufficient justification for a one-to-one
relationship was not provided and the limited available empirical data contradict the validity of
the assumed one-to-one relationship.
The Panel strongly recommends that the Agency expand its planned joint study with CPSC to
measure dislodgeable CCA chemicals from an appropriate sample of play structures, so as to
obtain information of more direct value for exposure assessment. Ideally CCA chemical
loadings on the hands (and possibly other skin surfaces) of children using play structures would
be measured in addition to corresponding dislodgeable residues. At a minimum, some Panelists
would accept gathering of data sufficient to more adequately support implementation of OPP’s
current conceptual model (e.g., matched adult volunteer hand and cloth wipe samples to better
establish the relationship between these two measures as well as the constancy of any
relationship as a function of surface area sampled).
The Panel was divided on an interim recommendation for the Agency while it awaits collection
of these additional data for the EPA/CPSC study. Some Panel members were willing to endorse
interim use of existing hand or fabric wipe data if described probabilistically. One Panel
member voiced strong opposition to any use of cloth wipe data until the Agency obtained
additional information establishing the validity of the assumption of a constant loading as a
function of wiped surface area. At least one Panel member opposed use of a “transfer
34
efficiency” approach, preferring a “transfer factor” approach which cannot be implemented
without further data collection.
Discussion
The Panel was not given any explanation or justification of how OPP’s Residential SOP – with
its assumption of a one-to-one transfer of pesticide residues from surface to skin – was derived
and whether there is general agreement on its principle and use. [Note: The SAP meeting at
which the proposed residential SOPs were discussed was held in September of 1999. The
reference to April, 2000 is unclear. No source bearing that date was provided as background
material or is cited in the background document.]
The Panel noted a number of factors that make an assessment of the appropriateness of a one-toone transfer relationship difficult. Variables that might influence surface-to-skin transfer include
the nature of the initial CCA treatment, type of wood (softwood, hardwood, etc.), condition of
wood (age, moisture content, etc.), orientation of wood member (vertical or horizontal), nature
of the surface residue (particle-bound, dissolved, crystalline, etc.), condition of skin (moist/dry,
intact/broken, clean/dirty), and nature of contact (pressure, duration, static/dynamic, etc.). The
Panel discussed the extent to which both published peer reviewed literature and new information
presented at the meeting provided empirical data for evaluating the assumed one-to-one transfer
of CCA chemicals from wood surfaces. Dr. Stillwell reported transfers of 30 to > 90% when
CCA chemicals were applied to a glass surface using his cloth swipe technology. The higher
levels of transfer were observed when using damp cloth. Similarly high transfer factors were
reported for a study (Rodes et al., 2001) with hand presses to remove household dust. This study
showed that the magnitude of transfer was sensitive to surface material (stainless steel > vinyl >
carpet) and hand moisture content (wet > damp > dry), although the applicability of this study to
dislodgeable CCA wood chemicals was unclear. The Panel was presented with an unpublished
study by Scientific Certification Systems (SCS, 2001) that compared loadings of hand swipes
versus “KimWipe” tissue swipes of CCA wood. This study reported that transfer efficiencies for
damp adult hands were lower than those observed using dry “KimWipe” tissue swipes of CCA
wood. Damp hand swipes were reported to be 7.5% of results obtained using “KimWipe” tissue
swipes of new CCA wood surfaces that had not been treated with a sealant. The damp hand
swipes were 44% of “KimWipe” tissue swipes of aged CCA wood. The Panel noted that these
comparisons reflect different surface areas swiped by hand (500 cm 2) versus tissue (100 cm 2),
and expressed concern over potential nonlinearity in loading as a function of surface area.
Exponent presented an analysis of existing data indicating that hand swipes were on average
about 25% of cloth/tissue wipes, but the Panel noted variability and uncertainties related to the
size of the surface area sampled, the type of contact and consistency across testers, and humidity
of contact surface confounded the interpretation of results.
One Panel member stated that the Agency’s proposed model for computing hand loading of
CCA chemicals appeared capable of substantially underestimating and overestimating the
amount of transfer, based on comparing predicted hand loadings from cloth and tissue swipe data
with observed hand loading data. The Panel member strongly urged the Agency to make use of
current data with both hand and cloth swipe data (e.g., Lu and Fenske, 1999; California DHS,
1987; SCS, 1998) to validate their conceptual model. It was emphasized that the assumption of
35
a constant transfer efficiency as a function of surface area wipe had not been established and
indeed there were data to argue to the contrary.
It was noted by the Panel that all the transfer studies discussed use the hand only, and the
transfer may be different with different body surfaces that may contact the wood. The issue was
also raised that there are no studies showing that transfer efficiency is constant across different
surface area sizes or types. It should also be noted that Rodes (2000) found that skin loading of
dust particles reaches a maximum after typically 4-5 contacts. After that, there may be
dislodging of particles from skin.
Addition of collection of hand wipe samples from children engaged in unstaged activity on play
structures has been recommended for the proposed CPSC-EPA field project. Wipe samples
should include body parts other than hands, or non-hand surfaces should be removed from the
dermal/dislodgeable residue scenario, as loading on body parts other than hands will probably be
much lower than loading on hands. If the Agency intends to do these transfer evaluations, it
needs to adopt an appropriate standardized sampling protocol for surface collection since that
will affect the outcome. Specifically, the Agency needs to include validation of the assumption
of constant transfer efficiency as a function of the sampled surface area.
In conclusion, the Panel agrees that a one-to-one relationship for transfer of residues from wood
to skin is not justified at this time. The Panel also agrees on the need to collect empirical data
that realistically reflect the activities of children on CCA-treated wood play structures and other
possible points of contact such as decks and walkways. If a probabilistic risk assessment is to
be conducted before new, relevant empirical data are generated, a wide range of possible transfer
efficiencies (TEs) should be used in a manner that reflect the uncertainty and variability in the
available data.
Question 10: The Panel is asked to comment on whether the proposed Soil Adherence
Factor (AF) of 1.45 mg/cm2 for hand contact with commercial potting soil is a realistic
value for use in estimating the transfer of residues from playground soil to skin in this
assessment.
Recommendation
Use of an AF of 1.45 mg/cm 2 is not recommended. The proposed AF was derived from an
unpublished study of very limited scope. EPA has funded subsequent research to derive more
representative values.
36
Discussion
The proposed AF represents a fairly high hand level and is too high for whole-exposed-bodysurface average. Soil loadings on non-hand body parts are typically lower than loadings on
hands. The soon-to-be-released RAGS Part E provides an estimate of a surface-area-weighted
average soil adherence factor for children. However that number reflects multiple activities on
multiple surface types. For purposes of evaluating use of CCA-treated wood in play structures,
consideration of media found under play structures is required. Adherence factors relevant to
loose media appear most appropriate. A possible alternative to the value recommended in
RAGS Part E would be the children-playing data from Kissel et al., 1998. Those data were
collected from 8-12 year olds playing in a bed of sandy loam installed in a greenhouse. (The
data can be downloaded from http://depts.washington.edu/jkspage/greenpost.html .) Most of the
data were collected under wet soil conditions. The wet soil data should be conservative for soil
and may be adequate for buffer materials. No data describing adherence of buffering materials
(bark, pea gravel, ground tires) to skin are known to exist.
The proposed dermal/soil scenario utilizes an absorption factor derived from 24-hour
experiments, implying that the exposure period is also 24 hours. Soil exposures occur
intermittently and are interrupted by bathing events. (For instance it is unlikely that soil loadings
equivalent to those observed in the greenhouse experiments noted above would be maintained
for 24 hours.) A probabilistic approach incorporating temporal description of both exposure and
absorption is preferable to the deterministic approach proposed by OPP. To the extent possible,
variation with age, season, and geographical region should also be incorporated.
Question 11: OPP will need to calculate intermediate-term, and possibly long-term
exposures in this assessment using available wood/soil residue data. The
Panel is asked to recommend a credible approach for selecting residue data
values for use in OPP’s risk assessment, taking into consideration the
inherent variability of the data sets. Please advise us on which values are
best for representing central tendency and high end exposures. Also, the
Panel is asked to discuss the feasibility of combining data from individual
data sets.
Recommendation
The proposed USEPA/CPSC study of wood and soil residues associated with CCA-treated
playground equipment provides a unique opportunity to generate a substantial data set on the
variability of residue levels for the playground scenario using a standardized sampling and
analytical methodology. This study should help to resolve uncertainty regarding the relative
contribution of true, inherent variability in residues versus variability due to differences in
methodology. It is critical, therefore, that the protocol be highly detailed regarding sampling
methods, locations, and frequencies and that the protocol be rigidly followed. Basic scientific
criteria for acceptance of the final data set should be laid out first and include: standardized
collection methods, precision, accuracy, reproducibility, and other measures of QA/QC.
37
The Agency should not combine data with quite differing levels of precision and
conservativeness, and use one set of data to drive other model considerations. The model cannot
be fully evaluated without real world (i.e., biomonitoring or soil consumption) data for
comparison, and that comparison cannot be made without a representation of both variability and
uncertainty in model outputs.
Discussion
There are few studies related to children’s playgrounds, and no study contains all of the data that
the Panel considers critical to getting an accurate determination of what children are being
exposed to on playgrounds and on CCA-treated decks. The Panel believes that separate studies
should be conducted (i.e., those looking at residue levels on playgrounds, and those examining
home decks and home playgrounds). The residue data should not be combined from decks and
playgrounds. Data from piers, walkways in wetlands, and similar structures do not fit the
playground scenario and should be ignored. The Panel recommends that the Agency expand the
upcoming study to 25 playgrounds and 25 home decks/home playground combinations in each
of the three U.S. study areas (e.g., Northeast) in order to determine what children are being
exposed to. An extensive sampling regimen must be undertaken.
The critical data required for risk analyses should include the following information and
samples:
• Soils selected should mirror those most commonly found in each region;
• History of the playground equipment (e.g., wood type, age, coatings/sealants etc.) must
be collected;
• Representative soils should be collected in order to determine speciation and profiles of
As, including organic arsenic species and chromium in the soil profile at each site; soils
must be collected from throughout the area below and adjacent to the play
equipment/deck and analyzed separately to determine the primary sites of residue levels
that are unique to each playground/deck studied; adequate control soils must be collected
from adjacent areas;
• Soils, including controls should be characterized thoroughly (e.g., clay, sand and silt
content, pH, organic matter, moisture, etc.);
• Wood borings from sections of the playground equipment known to have frequent
contact by children at play (this can be accomplished by video) for residue analyses
should be collected to determine residue levels in wood and relate these to residue levels
that have leached to the surface (the treatment process is not uniform due to knots,
growth rings, etc., and there probably are “hot spots” of As and Cr) (this is related to
Question 9);
• Wipes have been used as a means of determining dislodgeability, but there is no standard
technique that provides reliability and uniformity to data collected from various surfaces;
•
•
Consider collecting hand, arm and leg rinses from a representative sampling of children
playing on the equipment and tie these to biomonitoring analyses;
Analyses of buffering materials from play areas including borders should be included in
the study (related to Question 14).
38
Each of the available data sets should be critically evaluated to determine whether they have
been obtained 1) from a relevant structure and 2) using acceptable sampling and analysis
methodologies.
The following studies present some representative soil data and can be used until additional data
are collected:
• Playground equipment: Riedel, D. et al. 1991. Residues of arsenic, chromium and copper
on and near playground structures built of wood pressure-treated with “CCA” type
preservatives. Draft report to Health and Welfare Canada, 49 pp. (10 playgrounds
examined); Malcom Pirnie. 2001. Report results of soil sampling analysis. Chromated
copper arsenate treated wood at playground structures. Draft appendices. Prepared for
Am. Chem. Council. (4 playgrounds in U.S.)
• Decks: Stillwell, D. E. and K. D. Gorny. 1997. Contamination of soil with copper,
chromium and arsenic under decks built from pressure treated wood. Bull. Environ.
Contam. Toxicol. 58:22-29 (7 decks); Scientific Certification Systems. 2000. Study of
arsenic leaching into soils underneath CCA treated wood decks. Prepared for Osmose,
Inc., 47 pp. (10 decks 5-5 to 10 yr and 5-10 to 15 yr old); Townsend, T., H. SoloGabriele. 2001. Metal concentrations in soils below decks made of CCA-treated wood .
FL Center for Solid and Hazardous Waste Management, Gainesville, FL, 88 pp. (9
structures in FL).
The Agency asked for advice on values for best representing central tendency and high-end
exposures. The best measure of the central tendency depends on the shape of the distribution.
One Panel Member noted that it has been suggested (Crump, 1998) that the arithmetic mean, as
opposed to the geometric mean, is the preferred measure of central tendency for exposure when
the concern is for health effects. The best approach for estimating central tendency and high-end
exposures and for dealing substantively with the process would be a two-stage probabilistic
analysis that evaluates both variability and uncertainty. The use of distributional analyses for
CCA exposures should rely on firmly established and transparent criteria that are common to all
probabilistic analyses. Many of the same principles that have been incorporated into the
assessments of food and residential exposure guidance, for example, should be incorporated into
the CCA assessments. In order to do this it is important to develop clear and consistent criteria
for both the modeling process and methods for dealing with model uncertainty, model
variability, and input uncertainty. All three of these must be addressed systematically
throughout the process.
This three-point framework for describing model variability and uncertainty is based on the
points outlined in Cullen and Frey (1999), which is a useful guidebook and starting point for
addressing the issues raised by this question. Once these principles are clearly articulated and
inculcated, decisions based on application of this framework should be easier to justify.
Given the multiple models, data sets, and analyses involved in developing an assessment of
CCA, probabilistic methods are the preferred approach for estimating exposures and risks. That
said, the use of uniform distributions, which are generally used in cases where data are sparse or
inconsistent, are better than point estimates. Fitted distributions should be used when there is
39
some underlying rationale, such as processes driven by physical parameters where some data
exist or in cases where there are fairly good data, such as soil consumption rates. There are
several options for combining these data. When appropriate, multiple data sets could simply be
combined into a single, “global” data set that could be used as input for a probabilistic exposure
assessment. However, this simple approach ignores the “inadvertent” weighting associated with
combining data from experiments with different numbers of samples. Appropriate weighting
factors could be applied to each data set to correct for this effect.
Alternatively, weightings could be applied on the basis of a judgment concerning the
“representative nature” of a particular data set. The specifics of the approach for combining
these data should be determined by a qualified statistician in conjunction with scientists familiar
with the data. A similar analysis has previously been performed to obtain a “global” distribution
for the hair:blood partition coefficient for methylmercury (Clewell et al. 1999).
It is inevitable that dissimilar data will be combined once exposures are aggregated, but
uncertainty and variability should be distinguished. The Agency should not combine data with
quite differing levels of precision and conservativeness, and use one set of data to drive other
model considerations. The model cannot be fully evaluated without real world (i.e.,
biomonitoring or soil consumption) data for comparison, and that comparison cannot be made
without a representation of both variability and uncertainty in model outputs.
In performing a probabilistic analysis the Panel suggests using intervals (i.e., uniform
distributions) rather than point estimates when data are sparse/uncertain. This approach reduces
the burden of data collection and parameterization and, although it is simpler than second-order
Monte Carlo simulations that formally separate variability from uncertainty, it still distinguishes
the two. Using intervals in a Monte Carlo simulation avoids creating a mix of partially
probabilistic and partially deterministic estimates.
Question 12: Does the Panel have any recommendations for combining the four scenarios
(oral/wood, dermal/wood, oral/soil, dermal/soil) such that a realistic
aggregate of these exposure routes may be estimated?
The Panel offers the following recommendations:
• The Panel encourages the Agency to aggregate exposure estimates across all potential
sources. This should occur in a way that makes the contribution of various sources of
exposure transparent and tracks separate species of arsenic and chromium. Although data
at present are limited, it is possible that the different species of arsenic encountered from
distinct exposure scenarios may differ with respect to their hazard. For example, arsenic
in the form of a complex of copper chromated arsenate ingested from direct contact with
freshly treated wood might be metabolized and excreted differently than arsenate leached
from weathered wood and ingested incidentally in soil.
•
The suggested scenarios (oral/wood, dermal/wood, oral/soil, dermal/soil) capture the
exposures that may occur on playscapes and decks. Inhalation exposure may be a route
40
that should be included, however at this point in time, data are insufficient to estimate the
distribution of possible inhalation exposures. Refer to the response to question 13 for
further analysis.
•
However, in terms of the aggregate exposure assessment, the proposed scenarios do not
capture sources of exposure that appear to be significant. The Panel suggests that the
Agency broaden its inquiry to consider the diversity of possible exposures to arsenic,
chromium and copper. Some Panel members felt that the Agency should expand its
formal analyses of exposure to include other media under the jurisdiction of other EPA
offices—drinking water, air, and waste—to avoid a fragmented and incremental approach
to risk assessment and management of arsenic, chromium and copper species.
•
Probabilistic methods should be used to estimate exposure and risk. This demands
selection of best available data sets to construct distributions. This must be done with
considerable care. The EWG approach seems conceptually reasonable; however, their
method combines point estimates with distributions, and this may introduce bias into the
estimates. The Lifeline method is especially well adapted to aggregate exposures across
diverse routes, while preserving estimates at the level of the individual. The Agency
should be encouraged to develop this model in the immediate future while closing data
gaps.
•
Uncertainty should be carefully characterized, distributions characterized, and clear
criteria applied to judge the quality of available data for each parameter included in the
assessment. The Agency should further develop Table 4 in the EPA support document
Children’s Exposure to CCA Treated Wood Playground Equipment and CCA
Contaminated Soil. Table 8 in the Gradient Corporation submission provides a similar
model that attempts to identify ranges of factors potentially affecting exposure, tracks the
sources of data, and provides a preliminary characterization of uncertainty.
•
Regarding uncertainty and default assumptions the Agency should confront two
questions directly: When are data of sufficient quality to include in a modeling effort?
What should be done until data are adequate? The SAP provided the Agency with clear
criteria to judge data quality in 1999, and these were recognized in support documents
provided to this panel. Under conditions of moderate or high uncertainty (absence of
sufficient data to fully capture the variability in exposure from these sources), the
Agency should develop clear default assumptions to be employed until sufficient data are
secured. These assumptions should err on the side of overestimation of exposure, or
factors that contribute to exposure, and reduced if and when credible data are presented.
•
The Agency should develop methods that aggregate exposure and risk estimates for
individuals. These may then be aggregated by various demographic characteristics—age,
income, ethnicity, and location (north/south; urban/rural), or specific behavioral
characteristics.
41
•
The literature on childhood behavior and activity patterns that may be associated with
CCA exposures is quite young. It provides only a limited basis for understanding the
associations between behavior and exposure. The Panel recommends that the Agency
undertake studies of childhood behavior and activity patterns to clarify these possible
associations, as children move through their daily life. These studies would be useful in
EPA assessment of exposures to many different hazardous substances. The Agency’s
efforts in developing the Exposure Factors Handbook and the more recent Children’s
Exposure Factors Handbook are very positive and important contributions that support
data based, behavioral scenario-building.
•
The Panel anticipates considerable year-to-year variability in exposure among children
ages 1-6. Toddlers between 1 and 2 years of age play, behave, eat and dress very
differently than 6 year olds, and these are likely to affect contact with contaminated
media.
•
Residential, educational, day-care, recreational, and occupational environments all offer
the possibility of childhood exposures to CCA. Specific locations where CCA is in
common use include decks, playscapes, railings, docks, piers, pilings, fencing, and
exposed untreated interiors of structures, especially those close to the ground such as
sills. Picnic tables, mulch, and contact with wood scraps, smoke from intentional and
unintentional fires, and ashes from burned construction debris could all be sources of
exposure.
•
CCA-treated wood is increasingly being used for interior construction, and if unfinished
and left exposed, may be an additional source of childhood exposure. It would be helpful
for the Agency to estimate the extent of these uses.
•
The Panel encourages the Agency to consider possible high exposure scenarios defined
by overlapping risk factors. For example, a toddler living in the Southwest, may
experience high drinking water concentrations of arsenic. At the same time the warm
climate encourages extended periods of outdoor recreation. If this child is enrolled in a
day care facility with decks and play structures made from CCA-treated wood, the
aggregate exposure may be high. The identification of populations that are both
physiologically susceptible and highly exposed would provide a logical basis for strategic
risk management.
42
Question 13: Can the Panel comment on whether OPP should conduct a child playground
inhalation exposure assessment, taking into consideration the hazard profile
for chromium (VI) as an irritant to mucous membranes? If so, can the Panel
comment on whether the endpoint described above is appropriate for
assessing the risk to children from such an exposure?
Recommendation
The Panel notes that both the trivalent and hexavalent forms of chromium are of concern in the
inhalation route of exposure and that arsenic should also be considered in the inhalation route of
exposure.
However, the Panel agrees that calculations of probable exposure concentrations suggest that the
Agency should not consider the inhalation route of exposure to inhaled metals in their risk
assessment. The SAP strongly suggests, however, that exposure concentrations be monitored via
personal and area sampling to validate such a conclusion.
Discussion
The contribution of inhaled metals to the risk for children using playground equipment
constructed of CCA wood is dependent on the airborne level of metals. Unfortunately, there are
no data on the ambient concentrations of metals in the vicinity of CCA-wood play structures.
There is a need for determination of the range of background ambient exposure levels to
chromium and arsenic and to compare these values to potential exposure levels for a 15-kg child
during a 1-3 hours of play.
Soil in the immediate vicinity of play structures is frequently disturbed during child play and
inhalable particles can be resuspended and re-entrained in air. Although the question posed to
the SAP referred to the volatility of the inhaled metals, the primary concern is a resuspended dirt
scenario, and not the volatility of chromium and arsenic, which should be considered. The
questions posed to the Panel also referred to respirable particles. Most mechanically generated
particles are very large. Thus, inhalable (particles which can be inhaled into the nasal or oral
passages; generally less than 100 :m in aerodynamic size) and not respirable (particles which
reach the gas exchange region of the lung; generally less than 3 or 4 :m) particles are of concern
in terms of the nasal effects of chromium. These particles deposit in the nasal cavity, are cleared
towards the back of the throat, and swallowed, thus ultimately resulting in an oral delivery.
It is likely that the assumption of 100% hexavalent chromium is an overestimate of its proportion
in the soil and dislodgeable residue. In addition, there are very sparse published data on
hexavalent vs. trivalent chromium in CCA-treated wood and none (except for what was
presented by Drs. Stillwell and Townsend) for soil. Such a data set regarding the valence state
of chromium in soil needs to be developed.
Because no data have been developed for airborne metals in the vicinity of playgrounds built
with CCA-treated wood, one must use surrogate values to calculate a potential risk. The Panel
members introduced three arguments against the need for an inhalation examination of the
potential effects of playground exposure to chromium and arsenic. First, workers are exposed to
43
much higher concentrations of CCA-treated wood dust in occupational settings (Decker et al.,
2001) and the occupational exposure limit for chromium is not exceeded. It must be considered,
of course, that an occupational exposure limit (OEL) is set for a healthy adult worker over an 8hour period.
Second, using the NOAEL given in the EPA document for adverse nasal effects in workers, one
can calculate relative inhalable concentrations of chromium for a child. Using a rough
assumption of the volume of air inhaled by a child, the level of exposure to inhalable chromium
is insignificant:
•
Using the following rough assumptions, one can calculate that a 15 kg child inhales
approximately 5.4 m 3 in a 24 hour period:
0.25 l/breath x 15 breaths/min x 60 min/hr x 24 hour/day = 5.4 m 3.
•
Assumption of a NOAEL of 2.4 x 10 -4 mg/m 3 (noted in the EPA document) yields:
0.086 :g/kg-day for 24 hr (0.000086 mg/kg-day for 24 hr exposure) for a 15 kg child
or
0.0036 :g/kg-day for 1hr (i.e., 0.000036 mg/kg-day for 1 hour exposure).
Therefore, in comparison to the LOAEL of 0.05 mg/kg-day (or 50 :g/kg-day) considered in
Question 1, this exposure level is below that of concern.
Of course, an assumption of 2.4 x 10 -4 mg/m 3 as a NOAEL for hexavalent chromium could be
high, but as noted previously, it is unknown what the exposure levels are for airborne particles in
playground areas.
Third, one can calculate a worst-case scenario for inhaled resuspended soil and compare it to the
central tendency value for the oral ingestion of soil. If one uses a central tendency value of 100
mg soil ingested/day for a child (as suggested by EPA), this can be compared with the potential
concentration of airborne soil particles which would need to be inhaled to equal this amount of
soil delivered via the oral route. Using a rough assumption of 5 m 3 for the volume of air inhaled
in a day suggests that a child would have to be exposed to an airborne concentration of 20
mg/m 3.
100 mg/day / 5 m 3/day = 20 mg/m 3
This value of 20 mg/m 3 for inhalable particles is exceedingly high and is very unlikely in a
playground setting. It was noted by Panel members that the soil, sand, or buffering material
below the playground structure may influence the degree of resuspension of dislodgeable CCA
or soil.
Thus, it appears to be unlikely that an inhalation pathway needs to be considered in the EPA risk
assessment of the use of CCA-treated wood in playground settings. However, the Panel feels it
44
would be prudent to develop a data set for airborne/reentrained soil particles to validate this
recommendation. It is suggested that personal or area monitoring be added to the proposed
EPA-CPSC playground study. In addition, this data set should include airborne arsenic as there
is no justification to exclude it in an inhalable CCA-treated wood risk assessment.
Question 14: Data on the effectiveness of reducing exposure by using buffering materials
are limited. Does the Panel have recommendations as to whether additional
studies to obtain this information are warranted? Does the Panel have
suggestions on how OPP can best evaluate child exposures attributed to
contact with CCA-contaminated buffering materials?
Recommendation
The consensus of the Panel is that additional studies are warranted to obtain information needed
to assess the exposures associated with using buffering materials.
Buffering materials do not appear to provide a means to reduce exposures to CCA leached from
play structures. Rather, buffering materials can present important risk scenarios that differ from
the four scenarios currently proposed for analysis by the Agency. These additional scenarios
include: 1) exposure to buffer materials that become contaminated with metals from CCA
leached from play structures and 2) exposure to buffer materials that contain CCA because they
consist of recycled construction/demolition debris which contains CCA-treated wood.
Exposure to buffer materials that become contaminated with metals from CCA needs to be
examined. This effort should be aided by the generation of data describing the amount and
nature of exposure in young children who play on or with these materials. It may also be
possible to generate bounding estimates of exposure from these materials for the purpose of
screening the relative importance of this scenario compared to other play structure-related
scenarios.
Exposure to buffer materials that contain CCA-bearing mulch will likely result in a sufficient
hazard potential to warrant a modification of the recycling practices that lead to the introduction
of this mulch into children's play environments.
Discussion
Buffering materials refer to those materials that are placed below a play set to minimize injury in
the event of a fall. Examples of buffering materials include sand, pea gravel, wood mulch, and
tire chips.
There are two sets of issues imbedded in the concern over buffering materials. The first is the
potential that the materials can become contaminated due to their close proximity and contact
with CCA-treated wood play structures as CCA leached from the play structures coats the
buffers. The second issue is the potential presence of CCA-containing wood in construction
debris that is recycled into wood mulch used as buffering material. Both of these issues are of
45
particular concern because children may be attracted to the buffering materials due to their
unusual textures, colors, and ready availability. Therefore, where there is CCA contamination of
buffering materials, exposure potential to young children may be particularly high.
Regarding buffer materials that become contaminated by CCA leached from the play structure,
the following assumptions can be used to help conceptualize the issue:
•
Leached CCA forms a surface coating that is dislodgeable and thus available to children
who handle these materials. This implies that the proper way to analyze these materials
for the purposes of risk assessment is to find out how much dislodgeable residue is
present on the buffer material surfaces in ug/cm2 surface area as has been done with play
structure surfaces, rather than analyzing the entire material to get a ppm readout of
arsenic or chromium on a mass unit basis. Expressing the contamination as metal
concentration per surface area has the advantage of direct applicability to risk assessment
equations since children can be modeled to take up some or all of the dislodgeable
residue through mouthing behavior (putting entire chip or stone in mouth for brief
period) or via chip-to-hand transfer followed by hand-to-mouth behavior. However, it is
unlikely that children will actually ingest an entire chip and so the ppm type
measurement would be less relevant. The Panel noted that the Alachua County, Florida
data presented to the Panel, while limited in number of samples, suggested similar ppm
contamination of buffer material (shredded rubber in this case) as neighboring soil.
However, since buffers will not be ingested on a mg/day basis, the exposure implications
of ppm in soil and ppm in buffer are not the same.
The recommendation that comes from these considerations is that buffering materials that are
passive recipients of CCA leached from play structures should be chemically analyzed by
finding out how much dislodgeable metal is available per square centimeter surface area. A
suggestion for how to conduct this analysis is to put a representative number of chips/stones into
dilute acid solution to extract the metals, analyze the metal content in the extract (e.g., ICP) and
then calculate the dislodgeable residue by dividing the total metal extracted by the surface area
of the chips/stones placed into the dilute acid solution. This would result in an estimate of the
maximum metal loading concentration that children may dislodge onto hands or extract in their
mouth.
The Panel is not aware of any survey or videotaping data of children’s behaviors with respect to
buffer materials. Therefore, exposure assessment in this area will be uncertain and data
collection is important. The most direct and empirical form of data collection may be the
sampling of children’s hands and other exposed dermal surfaces at the end of a play event to find
out how much of the dislodgeable material (measured by analyzing the buffer materials as
described above, from various portions of the playground) is transferred onto children’s hands.
This may allow for an estimation of buffer-to-hand (or skin) transfer efficiency. Given that this
transfer will be highly age and behavior dependent (types of interactions with the buffer
materials and location on playground where child interacts with buffer), there will be much
variability in the data. Therefore, a sizable dataset would be needed to obtain a representative
distribution of dermal loading per play event. The value of such distributions obtained in this
46
way is that they could be suitable inputs to probabilistic (Monte Carlo style) exposure
calculations.
Another option for data collection pertinent to this exposure scenario is obtaining observational
(e.g., videotape) data on children’s play activities to compile information on the frequency of
contact with the buffer materials and classification of contact into categories such as superficial
(brief touches) vs. intimate (handling/playing with the chips) vs. mouthing of chips. This
information could then be combined with study data on how much CCA is dislodged from the
chips from superficial vs. intimate vs. mouthing of chips in studies involving children or adult
volunteers performing these types of activities. Of course, the mouthing of chips would not be
performed but would have to be simulated in some way or assumptions used regarding percent
extraction of residues from chip/stone residence for brief periods in the mouth.
Actual empirical data are most desirable for input into this or any other human health risk
assessment. However, to evaluate the need to collect field data and perform a refined analysis
for this particular scenario, the Agency may want to consider performing bounding, screening
level calculations. Given that without the types of empirical data described above there will be
greater uncertainty in exposure estimates, the defaults used should necessarily be high-end
bounding assumptions. Such assumptions may look like the following:
•
The dislodgeable residue loading on wood/rubber/gravel buffers is equal to the
dislodgeable residue on the wood play structure. This may tend to be a reasonable upper
bound on the relationship between wood structure to recipient buffer material loading
since the buffer material will not only receive leached CCA but will also have such
residues washed off in rain events, and so some equilibrium (probably no higher than
what is on the donor wood) would be established on the buffer materials.
•
The chip-to-hand transfer efficiency is 1:1, that is, whatever surface loading that is
assumed to be on the chips will also exist on the hands. This assumption implies intimate
contact with the chips such that the hands would be in equilibrium with the chips. Lower
levels of loading are also possible from less intimate contact but would not represent an
upper bound default. Higher levels of loading in which the hand actually accumulates
dislodgeable residue might also theoretically occur, but empirical data would be needed
to find out the circumstances under which this might be possible.
•
Mouthing of chips/gravel would extract all the dislodgeable residue from that buffer
material; the amount of residue available is based upon the surface area of the chip
(empirical measurements for different buffering materials should be used) and the
loading on the chip (as discussed above).
•
The Panel did not have an opportunity to explore what might be reasonable bounding
assumptions on frequency of mouthing behavior, time spent playing in chips relative to
time spent on play structure itself, hand-to-mouth frequency, etc. (This might be based
upon the same videotaping studies used for the hand-to-mouth assumptions for children
on play structures.)
47
In summary, the Panel recommends that empirical data be gathered with respect to children’s
exposures to dislodgeable residues of CCA from buffer materials via actual children’s play
studies or from observational data on children’s play behavior combined with data describing the
range of chip-to-hand transfer for different degrees of contact. An additional study design
mentioned during Panel deliberations was to have a single playscape underlain with differing
buffering materials including no buffer (native soil) around different portions of the play
structure. After a period of environmental loading and equilibration of buffer material, then
children could be instructed to play on one of the buffer types to allow a comparison of exposure
potential across the range of different materials.
Whatever study data are generated, they should be of sufficient diversity and robustness to
characterize the distribution of behaviors and residue transfer efficiencies. However, if
appropriate empirical datasets are not available for probabilistic assessments, EPA may consider
the option of screening level deterministic assessments using reasonable upper bound defaults
based upon available empirical data.
The possibility that these buffers might lead to a decrease in exposure to CCA relative to native
soils does not look promising, based upon the evidence that leached CCA can lead to elevated
arsenic concentrations near CCA-treated wood structures (Alachua County data). However,
additional studies along these lines or as described above may better answer this question.
Unfortunately, when construction debris is recycled into mulch, a percentage of the wood may
contain CCA. Data are available (Tolaymat et al., 2000, Townsend et al. 2001, and SoloGabriele 1998, 1999) that indicate that CCA-treated wood is found in mulches produced from
construction and demolition facilities within Florida. During 1996, the mulch from 12 different
construction and demolition facilities was found to contain 6% CCA-treated wood by weight, on
average. A study at 3 facilities during 1999 found that concentrations of CCA-treated wood in
mulch varied between 9 and 30%. Mulch samples collected from retail establishments showed
evidence of CCA as observed by arsenic leaching tests.
If CCA-wood bearing mulches are used as buffering material under play structures, then there
could a higher exposure potential from children’s hand contact and mouthing of CCA wood
mulch. As the wood degrades into smaller pieces and dust, there might be a higher opportunity
for bulk ingestion of material containing high concentrations of metals both from direct
mouthing of small objects and from hand to mouth transfer. Additionally, the dust generated
from playing with the mulch might become an inhalation risk issue, particularly with respect to
the Cr(VI) that may be present in the dust particles.
Rather than conduct a risk assessment on this portion of the scenario, the Panel recommends
survey, intervention, and education activities on the part of the Agency, perhaps coordinated
with other agencies, to prevent this exposure pathway to the extent possible. The survey would
be of the wood mulch marketplace to determine to what degree CCA-treated wood enters the
playscape environment, including practices at the municipal and homeowner/residential levels.
This survey information should be followed with focused intervention and education/warnings to
48
prevent or modify the practices that lead to this type of wood entering children’s play
environments.
Question 15: The Panel is asked to comment as to whether stains, sealants and other
coating materials should be recommended as a mitigation measure to reduce exposure to
arsenic and chromium compounds from CCA treated wood. If so, can the Panel comment
on the most appropriate way for the Agency to recommend effective coating materials
when the current data on long-term performance are limited and sometimes inconsistent,
and should the Agency specify a time interval for the re-application of these selected
coating materials? Can the Panel make recommendations for additional studies?
Recommendation
The Panel offers the following conclusions and recommendations:
• The Panel recommends that the EPA inform the public of the ability of certain coatings
to substantially reduce leachable and dislodgeable CCA chemicals and thus reduce
potential exposure to arsenic and chromium. While the Panel makes recommendations
below regarding the need for additional studies in this area, it feels that the current
evidence is sufficient to begin advising the public about the use of coatings now.
• The weight-of-evidence from available studies indicates that certain coatings can
substantially reduce dislodgeable and leachable CCA chemicals.
• Reductions of 70 to 95% in dislodgeable arsenic were seen in all studies that subjected
CCA wood to natural weathering.
• There is no evidence that water repellents added directly to the CCA treatment solution
are effective in reducing leachable/dislodgeable CCA chemicals;
• Current data are not adequate for identifying a particular coating as being clearly superior
or inferior to reducing leachable/dislodgeable CCA chemicals.
• Confidence is highest for polyurethane as this coating has been shown to result in
substantial 70 to >95% reduction in dislodgeable arsenic in a well controlled field study,
a “real-world” application allowing for effects of use, and a short-term controlled
laboratory study.
• Current data support a treatment frequency of once per year, although for some products
this may be too frequent (e.g., possibly polyurethane where one study noted up to 95%
reduction in dislodgeable arsenic out to 2 years). This is an area in need of additional
study.
• More studies are needed to evaluate the performance / efficacy of different types and
brands of coatings.
49
Discussion
Important definitions when evaluating coating data include the differences between treated and
untreated wood. Treated wood typically implies that the wood is CCA treated. Untreated wood
refers to virgin wood without the addition of CCA wood treatment chemicals. Both treated and
untreated wood can be either coated or uncoated. Coatings or sealants refer to paints, stains,
varnishes, and polyurethane resins applied to wood surfaces. For years the manufacturers of
CCA wood have recommended the use of surface coatings to reduce the checking and cracking
of wood resulting from effects of weather, such as rain, temperature, humidity, solar radiation
(http://www.preservedwood.com/faqs/faqs.html ). Intuitively, reductions in leachable and
dislodgeable CCA chemicals should be expected to the extent that coatings establish a barrier to
moisture contacting and entering wood and as a barrier to direct hand contact with the wood
surface. Likewise, the surface area available for leaching, including access to deeper wood
layers which are less depleted of CCA chemicals, should be reduced given that such coatings
reduce checking and cracking of CCA wood.
Evaluation of Coating Data
Sealant studies evaluated were separated into three groups: Studies that evaluated the impacts of
coatings on dislodgeable arsenic, impacts on leaching of arsenic, and related studies.
Studies available to the Panel that evaluated the impact of coatings on dislodgeable arsenic
included: Stilwell 1998, Scientific Certification Systems 1998, California Department of Health
Services 1987, and the Consumer Products Safety Commission 1990. Stilwell, 1998, evaluated
boards with four different coatings (polyurethane, latex/acrylic, oil stain, and spar varnish). His
results indicate that these coatings remained very effective in reducing dislodgeable CCA
chemicals for at least one year after they are applied. This study did not evaluate the
performance of sealants beyond one year. The boards were subjected to natural weathering
processes but the study did not include the effects of wear from human use. Also, the
experimental design would have benefited with the inclusion of a temporal control.
The SCS 1998 study evaluated the impacts of two post-treatment coatings (Superset stain, 3M
clear sealer/polyurethane -) and one coating incorporated into the CCA-treatment process
(Osmose water repellent). The other two coatings were applied after the wood was CCAtreated. The SCS study was a laboratory-based study using a series of boards. It is assumed that
the measurements of the dislodgeable arsenic were taken shortly after the coatings were applied.
Wear and tear from human use was not simulated, nor was rainfall or other weather related
effects taken into consideration. Results from this study were variable indicating that the 3M
polyurethane sealant was effective at reducing dislodgeable arsenic whereas the Superdec stain
and the Osmoses water repellent were not effective. Results from this work suggest that there is
variability in the reduction of dislodgeable arsenic by different types and brands of coatings.
The California Department of Health Services 1987 study was the only study that evaluated
structures (a fishing pier treated with polyurethane and a playset treated with an oil-based stain)
that were in current use and therefore included the effects of wear and tear upon the efficacy of
the coatings. Results of this study suggest that coatings provide a considerable reduction in the
amount of dislodgeable arsenic and, in the case of polyurethane, out to two years post-treatment.
50
One drawback of the study is the lack of an uncoated temporal control. However, the decrease
in dislodgeable arsenic was very large that even in the absence of such a control, the data are
considered to be meaningful.
The last study, sponsored by the Consumer Products Safety Commission in 1990, evaluated an
oil-based stain and a water repellent in a laboratory setting. The results of this study were
variable which is reflected in the high standard deviation observed in the uncoated CCA-treated
control. This variability confounds the ability to interpret the data and therefore the results are
considered inconclusive.
Only one study, Cooper et al. 1997, evaluated the ability of coatings to reduce the leachability of
arsenic from CCA-treated wood. This study evaluated the ability of Thompson’s water seal
(applied after CCA treatment) to reduce leaching of CCA from fences. The efficacy of water
repellents applied as part of the CCA treatment chemical were evaluated for fences and decks.
Results show that Thompson’s water seal (applied after CCA treatment) significantly reduced
the quantity of arsenic for a period of two years after the application of the water seal. The water
repellents applied as part of the CCA treatment chemical were not effective at reducing
leachable arsenic concentrations.
Related studies cited as part of the EPA review include Riedel et al. 1991 and Lebow and Evans,
1999. Riedel et al., 1991, focused on collecting dislodgeable arsenic data from 10 CCA-treated
playsets. Some playsets were coated with sealants and some were uncoated. This study is useful
in providing a range of dislodgeable arsenic variables from playsets. However, there are many
confounding factors when comparing the coated set of playsets with the uncoated sets. These
confounding factors include differences in retention levels between one playset and another,
wear and tear, locations sampled, and absence of any information on time elapsed from when a
coating was last applied. Given these confounding factors it is difficult to conclude whether or
not coatings reduce the quantities of dislodgeable arsenic.
Lebow and Evans et al., 1999, evaluated the use of an innovative pre-stain (water soluble acrylic
polymer with an iron oxide) which was applied prior to treatment with CCA. Results from this
study found that the pre-stain was able to reduce the release of arsenic by 25 to 30%. This was a
laboratory study that simulated natural rainfall over a 17-week period.
51
Conclusions from studies
Table 1 summarizes design features of the various studies and results in terms of percent
reduction in dislodgeable or leachable arsenic. Results of these studies as a whole support that
surface coatings (applied after CCA treatment) are effective at reducing the quantities of
dislodgeable and leachable arsenic. Reductions of 70 to 90% in dislodgeable arsenic were
observed across the studies as CCA-treated wood was subjected to natural weathering.
Conflicting results were obtained from the laboratory studies. It is noted that no studies looked
at both dislodgeable and leachable arsenic fractions. The current data are not sufficient to
identify a superior coating. The evidence is strongest for polyurethane, based on results from
Stilwell 1998, California DHS 1987, and SCS 1998. Future experiments should evaluate the
efficacy of different types of brands of coatings on both the quantities of dislodgeable and
leachable arsenic. Such studies should include a validated and consistent measure of
dislodgeable (e.g., Stilwell, 1998) and leachable CCA chemicals and should evaluate
performance over at least a 2-year and preferably a 3-year period. Furthermore, studies should
also focus on the durability of the coatings when subjected to wear and tear and include natural
weathering conditions.
The Panel recommends that the Agency inform the public of the potential benefits associated
with coatings in reducing leachable and dislodgeable CCA chemicals. Polyurethane should be
recommended for the time being. It should be also mentioned that other coatings show some
promise including acrylic/latex, oil-based stains, and some consumer applied water sealants,
although data are more limited. Furthermore, recommendations should mention that some
coatings will change the surface properties of the wood making it necessary for additional
traction on floors and deck portions of playsets. It is recommended that the decks be sealed at
least once per year. More definitive information concerning the use of coatings should be
provided to the public once additional data are available.
One Panel member recommended that the coating applied be clearly visible so that the effects of
wear can be easily observed. The Panel member indicated this is especially important in light of
the fact that there are limited data on the durability of the coatings against wear. In areas of
heavy wear, the coating should be applied more frequently than once per year if the coating is
visibly removed from these high-wear areas.
Another Panel member, who supported the use of coatings, voiced the concern that the CCA
chemical may accumulate below the coatings which if pealed and ingested could result in an
elevated risk to children. This comment emphasizes the need to periodically inspect the coatings
to minimize this potential exposure route.
It is important to keep in mind that none of the studies cited in this review have been published
in peer-reviewed journals. The strength of the overall conclusions made through this review
relies on the relative consistency between the results observed between some studies.
52
Table 1
Study
Design
Weathering
Sampling
Treatments
Stilwell, 1998 Purchased boards, placed
(CT)
outside, 4 coatings,
4 replicates, 5 time points
out to 1 year
Polyurethane, acrylic
latex, Spar varnish,
Oil-based stain.
Brush applied, 2
coats.
California
DHS, 1987
(CA)
Polyurethane, no
information on
application methods
California
DHS, 1987
(CA)
Standardized
Outside,
natural weathering, wipe method.
Repeat rubbing
no human use
of same surface
under controlled
pressure
Gauze wipe, 100
Outside,
Fishing pier, 1 coating,
4 replicates, 2 time points natural weathering, cm2 with repeat
rubbing to same
in use
out to 2 year
surface
Outside,
Single playground, 1
natural weathering,
coating,
? replicates, 3 time points, in use
out to 2 years
Gauze wipe, 100 Oil-based stain, no
cm2, with repeat information on
rubbing of same application methods.
surface
Kimwipes,100
cm2, damp. Hand
wipes, 500 cm2,
repeat rubbing of
same surface
Laboratory
Collection of
simulated aging,
natural rain water
plus outside,
contacting wood
natural weathering, surface
no human use.
3M sealant, Superdec
stain, no information
on application
methods, Osmose
water repellant
Thompson's Water
Seal (fence only) &
Water Repellent in
CCA treatment soln
(fence & deck).
SCS, 1998
(lab)
Purchased boards, used in
laboratory, 3 coatings,
5 replicates, 1 time point
apparently soon after
coating applied.
Cooper et al., Laboratory prepared wood,
1997 (New fence & deck structures,
Brunswick,
placed outside, 1 coating,
CAN)
? replicates, 2 time points,
4 mo, 2 yrs
Inside,
no weathering, not
subject to human
use.
Riedel et al.,
10 playgrounds, 2 to 10
1991 (Ontario, years old. Some stained /
CAN)
painted, others not. 4
sampling points per
structure.
CPSC, 1990 Purchased boards, used in
(lab)
laboratory, 2 treatments,
3 replicates, 2 wood types.
Lebow and
Laboratory prepared wood
Outside,
Gauze wipe, 250 Oil based stain on
natural weathering, or 500 cm2 with some though not all
in use
repeat rubbing of structures.
same surface.
Inside, no
weathering, not in
use, no aging
Laboratory
Nylon cloth
wipe, 400 cm2
Collection of
Oil-based stain, water
repellant, applied per
manufacturer’s label.
Water soluble acrylic
53
Results
Comments
> 95% reduction for
polyurethane, acrylic resin,
and varnish at all time points
as compared to pretreatment.
80-97% reduction for oil
stain.
> 95% reduction at 2 years as
compared to pretreatment
levels.
Does not account for wear.
Lacks temporal control.
Aesthetic problems after 1 yr
for spar varnish.
> 95% reduction at 6 months
as compared to pretreatment
levels. 70% reduction at 2
years.
Considers wear.
Lacks temporal control.
Limited sample sizes and
coatings.
Considers wear.
Lacks temporal control.
Limited sample sizes and
coatings.
Variable within type of coating.
Does not account for wear. Not
subject to natural aging and
weathering. Short-term
evaluation.
70% reduction at 4 months
Does not account for wear.
and 80% reduction at 2 years Includes temporal control.
for Thompson’s.
No reduction for water
repellent added into treatment
solution.
4 structures treated with stain Cross-sectional study with no
had on average 74% lower
site specific controls. Limited
levels of dislodgeable As than information on past application
average of 3 structures
of coatings. Sampling locations
without any coating. a
vary across sites.
No clear evidence of
Considerable variability in the
reductions.
controls, short-term study with
no weathering.
25-30% reduction in total As Coating applied pre-CCA
60% - 80% reduction for 3M
sealant as compared to
pretreatment. No reduction
for stain or water repellent.
Evans, 1990
1 treatment,
? replicates,
1 time point at 17 weeks
simulated rainfall
for 17 weeks.
natural rain water polymer applied pre- leached in artificial rainfall.
contacting wood CCA treatment.
surface
treatment, so of limited
relevance to post-treatment
coatings.
Estimate of 77% reduction based on comparing mean or the means for playgrounds designated A, B, and H (reported as no prior treatment with stain or paint) to
mean of means for playgrounds designated as D, E, G, I and J (identified as having a stain applied). Playgrounds C and F not included because of ambiguity
about application of stains. 50-60% reduction in leachable arsenic suggested from comparison of data on soil samples.
54
ADDITIONAL PANEL RECOMMENDATIONS
A.
Biomonitoring study
Recommendation
The Panel recommends that a biomonitoring study of children normally exposed to CCAtreated play equipment and decks be conducted. This study should be designed according to
well-accepted epidemiological principles, with adequate sample size, to resolve the issue of
whether there is substantive exposure of children to arsenic (and possibly chromium)
residues. The study should include urinary arsenic measurements as a biomarker of
exposure. If practicable, skin wipe samples should be collected in the same study. It would
be used to provide exposure information that could be used directly in the risk assessment
and also to validate the proposed exposure models.
Planning and study design should begin immediately, as there is a need for such information,
irrespective of the final form of the proposed exposure models.
Discussion
In the course of its deliberations the Panel noted two particular things: Firstly, the high degree of
uncertainty inherent in the assumptions and default measures proposed for use in the exposure
assessment pathway. The cumulative uncertainty in the resulting exposure assessment (and,
therefore, the risk assessment) was likely to be substantial. Secondly, the Panel noted the
absence of data on exposure of children to arsenic and chromium residues from playing on CCAtreated playground equipment and decks.
There was general consensus that there was an urgent need to obtain biomonitoring data for two
main purposes: to obtain data that could be directly used in risk assessments and to validate the
exposure assessment models.
The ultimate risk assessments that would employ the exposure data would be of two kinds: risk
assessments involving acute or short-term toxicity endpoints and assessments of chronic toxicity
endpoints, particularly carcinogenicity. The former would involve relatively large differences in
exposure between children exposed and unexposed to CCA-treated timber structures. These
differences could be detected in studies using smaller numbers of children than would be
necessary for assessments of carcinogenic risk, when smaller incremental exposures might be
important.
Concerns about the potential difficulties of carrying out epidemiological studies of this nature
were raised. These included the possibility of confounding by other sources of arsenic exposure
and whether it would be possible to obtain a representative sample of children.
In response, it was pointed out that other exposures to arsenic would only cause confounding if
they were correlated with exposures to arsenic from CCA. A priori, this seemed unlikely.
55
Provided a sufficient sample size was used and data on any potential confounding factors were
collected, confounding would not necessarily be a problem and, if necessary, could be adjusted
for in the statistical analysis.
In regard to whether a representative sample was necessary, it was agreed that such a sample
should not be necessary in the first instance, as the primary issue was one of causal inference –
whether there was evidence that children were substantially exposed to arsenic and chromium
from CCA-treated timber. A first study could be done in a potentially “worst case” situation. If
such a study provided evidence of minimal exposure then it would be likely that children
actually did not receive substantial exposure to residues from CCA-treated timber. On the other
hand, if such a study did show evidence of exposure then further studies in other settings would
be appropriate for refinement of the exposure assessments.
Ideally, the proposed study would include collection of skin (particularly hand) wipe data from
the children. This could lead to an improved understanding of the relationship between skin
exposure and actual absorption. However, it is important that collection of such wipe samples
does not lead to underestimates of the amount of arsenic absorbed and that the collection process
does not alter the normal play activities of the children.
It was generally agreed that such studies, involving children, are inherently difficult and need to
be designed and carried out very carefully. Because of the potentially long lead time for such
studies, it is advisable to begin the planning process for such a study as soon as possible. At the
same time, the risk assessment process should not be delayed pending final results of the
biomonitoring study.
B.
Effects of Metal-Metal Interactions on Toxicokinetics of Arsenic from CCAContaminated Materials and Environmental Media (Soil, Dislodgeable Material)
Recommendation
Detailed information must be provided about total composition of metals and metalloids that are
introduced into CCA-treated wood and that are present in contaminated soil and dislodgeable
materials. Information about known interactions between arsenic, chromium, and copper should
be included into the risk assessment related to CCA-treated wood. Additional studies are needed
to obtain more data about chemical and biological interactions of arsenic, chromium, copper, and
other metal (metalloid) contaminants found in CCA-treated (contaminated) materials.
Discussion
Exposures to CCA-treated wood components or to CCA-contaminated environmental media
represent in fact combined exposures to three metals (metalloids), arsenic, chromium, and
copper. It is generally recognized that biological effects associated with a co-exposure to a
mixture of metals may significantly differ from effects caused by an exposure to each metal
separately. The presence of chromium and copper may affect toxicokinetics (e.g., absorption,
tissue distribution/retention, biotransformation, biliary and urinary excretion) of arsenic and vice
56
versa. Because bulk chemical agents are used for the CCA treatment, other minor chemical
contaminants are also of concern in their effect on the subsequent disposition of arsenic with coingestion by exposed children.
Metabolic and toxicological interactions between the three major metallic components of the
CCA mixture have previously been reported:
• Co-exposures to arsenic are known to cause a profound accumulation of copper by the
kidney cortex (Ademuyiwa, et al., 1996). Although, copper is a relatively nontoxic metal,
possible adverse consequences associated with its accumulation in the kidney should be
considered under these exposure conditions.
• Co-exposures to arsenic affect tissue levels of chromium in laboratory animals with no
significant effects on hypoglycemic properties of inorganic chromium (Aguilar et al.,
1997).
• Combined acute exposure to Cr(VI), arsenate, and copper causes a marked decreased in
fetal weight and increased incidence of fetal resorption and abnormality formation in rats,
while none of the metals is teratogenic when administered (i.p.) separately (Mason et al.,
1989).
One concern is the extent to which impurities would affect the process of biliary excretion of
arsenic. Any effect on biliary excretion, for example, would complicate easy comparisons and
computational adjustments for biliary excretion when doing relative bioavailability studies. That
is, these substances would affect arsenic in dislodgeable residues or receiving soils but obviously
would not affect any toxicokinetics of the reference, soluble As(V) or As(III) dosing solution.
This creates a miscomparison. For example, inorganic selenium is known to modify excretion of
arsenic in bile. It has previously been shown that the biliary excretion of arsenic is strongly
dependent on glutathione levels in hepatic tissue (Gyurasics et al., 1991). Co-exposures to
selenite dramatically increase levels of arsenic in bile in rats (Gregus et al., 1998). Metabolic
interactions between arsenic, selenium, and glutathione are responsible for this effect. A
complex, seleno-bis(S-glutathionyl) arsinium ion, has recently been identified in the bile of
rabbits injected with selenite and arsenite ( Gailert et al., 2000). Similar biliary interactions have
also been reported for other metalloids (Gregus et al., 1998). Although effects of copper and/or
chromium on biliary excretion of arsenic are unknown, a report of Peoples et al., (1979)
provided to the Panel indicate that they exist. Here, dogs were fed with food containing sawdust
from CCA and ACA treated wood. The first dog received 6 mg As in CCA sawdust; the second
dog received 13.2 mg As in ACA sawdust (ACA does not contain chromium). Based on urinary
excretion, about 40% of the arsenic dose was absorbed in the first dog over 8 days. In contrast,
about 60-70% was absorbed in the second dog, indicating that the presence of chromium in CCA
sawdust may decrease absorption and/or urinary excretion of arsenic. The fact that these are oneanimal and one-dose data prevents more extensive evaluation of these results.
Other interactions with arsenic that are of concern are those that may potentially affect uptake of
arsenic in various media as a function of nutritional status. As noted in responses to Question 2,
the arsenic pathway interacts with the phosphorus pathway in biological systems so that a child's
57
nutritional status with respect to phosphorus deficiency or adequacy could possibly affect the
parameter of arsenic uptake.
C.
Bioavailability of Dislodgeable CCA Residues
The Panel agreed with the Agency’s decision to assume on an interim basis 100% relative
bioavailability of ingested dislodgeable CCA residue. During the public comment period, results
of an unpublished study were presented in which the absolute oral bioavailability of dislodged
material from CCA-treated wood was measured in hamsters. The Panel recommended not using
this information in the risk assessment at this time because the material dosed has not been
characterized and concerns about the animal model. However, the Panel recognizes that oral
absorption is a critical variable in the assessment of dose from oral exposure to CCA residues
and encourages further research to characterize it.
58
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63
Attachment 1 for Appendix F
The Office of Pesticides Programs (OPP) Responses to
Scientific Advisory Panel (SAP) Recommendations for
CCA Children Exposure and Risk Assessment
The Office of Pesticides Programs (OPP) Responses to Scientific Advisory Panel (SAP)
Recommendations for CCA Children Exposure and Risk Assessment
OPP Questions to SAP
1.
Please comment on the choice of this
data set and value chosen for
representation of the relative
bioavailability of inorganic arsenic from
ingestion of arsenic-contaminated soil.
Please discuss the strengths and
weaknesses of the selected data and also
provide an explanation as to whether this
25% value is appropriate for estimation
of bioavailability in children.
SAP RECOMMENDATIONS to OPP
!
!
!
Four different suggestions 25%, 50%., 25 to 50%, 098%
Oral absorption of arsenic from soil, consideration
should be given to absorption of arsenic from nonsoil
substances (such as wood chips or other buffer
material) that might be subject to incidental ingestion.
Research is needed to obtain data on the relative
bioavailability of arsenic from numerous sites that
encompass the broad range of soil types and arsenic
contamination specifically resulting from CCA-treated
wood applications. These studies should be conducted
in appropriate animal models preferably at doses that
simulate the anticipated level of exposure of children
playing on or around structures or sites subject to
CCA contamination.
OPP RESPONSE
?
?
As suggested , a study of
relative bioavailabile
study of arsenic in soil
affected by CCA- treated
wood and wood residues
collected from surface of
CCA-treated wood were
conducted in juvenile
swine. (ACC, 2003)
As suggested , a study of
relative bioavailabile
study of arsenic in soil
affected by wood
residues collected from
surface of CCA-treated
wood were conducted in
juvenile swine (ACC
2003)
OPP Questions to SAP
2.
3.
SAP RECOMMENDATIONS to OPP
Please comment on the Agency's
selection of the 0.05 mg/kg/day LOAEL
value for use in assessing risks to the
general population as well as children
from short-term and intermediate-term
incidental oral and dermal exposures, and
the appropriateness of the use of a 10x
factor for severity of the toxic effects
observed in the Mizuta study. Please
provide an explanation and scientific
justification for your conclusions as to
whether the presented data are adequate
or whether other data should be
considered for selection of this endpoint.
!
Please comment on the selection of the
value of 6.4% for dermal absorption of
inorganic arsenic and whether or not this
value will be appropriate for use in all
scenarios involving dermal exposure to
arsenic from CCA-treated wood,
including children’s dermal contact with
wood surface residues and contaminated
soils.
!
!
!
!
OPP RESPONSE
0.05 mg As/kg per day is an appropriate LOAEL for
short- (1 to 30 day) and intermediate- (31 to 180 day)
human ingestion of the chemical.
MOE of 30 from this LOAEL is recommended for
non-cancer health effects
MOE of 10 is also suggested by some panel members
?
As suggested. A LOAEL
of 0.05 mg As/kg per day
with a MOE value of 30
will be used for short- (1
to 30 day) and
intermediate- (31 to 180
day) human ingestion of
As.
In the range 2-3%, for dermal absorption of inorganic
arsenic should be used.
Using arsenic in more appropriate chemical form (that
it is present in dislodgeable CCA residues and in soil
beneath CCA-treated sites) and in a relevant matrix,
should be carried out to improve estimates of dermal
absorption.
?
As suggest, 3% will be
used in the risk
assessment for children
playing around
playground equipment.
As suggested , a study of
dermal absorption of
arsenic in the wood
residue collected from the
surface of CCA-treated
wood was conducted.
?
OPP Questions to SAP
4.
5.
SAP RECOMMENDATIONS to OPP
As available monitoring data do not
differentiate among chromium species
found in CCA dislodgeable residues on
wood surfaces and in soils, and as Cr
(VI) is the more toxic species of
chromium, please comment on whether
use of the hazard data for chromium (VI)
is the best choice for characterizing
hazard and risk from exposure to
chromium as a component of
CCA-treated wood. Please provide a
scientific explanation and justification
for your recommendation on the choice
of either the chromium (III) or chromium
(VI) hazard database..
!
Please comment on the Agency’s
selection of the 0.5 mg/kg/day NOAEL
value for use in assessing risks to the
general population as well as children
from short-term and intermediate-term
incidental oral exposures to inorganic
chromium as contained in CCA-treated
wood. Please provide an explanation and
scientific justification for your
conclusions as to whether the presented
data are adequate or whether other data
should be considered for selection of
these endpoints.
!
!
!
OPP RESPONSE
One approach would be to use an estimate of 25 to
50% hexavalent chromium. Some Panel members
suggested 5 to 10% would be conservative.
The Panel strongly recommends that EPA conduct
studies of chromium speciation (in both dislodgeable
residues and soil samples) in their proposed studies..
?
As suggested , 10% will
be used in the risk
assessment.
The Panel expressed concerns regarding the selection
of the 0.5 mg/kg/day NOAEL for short-term and
intermediate-term incidental oral exposures to
inorganic chromium. In general, these concerns
involved the appropriateness of the study selected by
EPA (Tyl, 1991) to derive this value. It is the Panel’s
recommendation that the Agency re-review the
literature and consider other potentially more relevant
studies.
The Panel questioned whether the study proposed for
the derivation of the NOAEL (Tyl, 1991).actually
demonstrated the purported effect. The Panel was
divided on this issue; some thought the study adequate
and appropriate to support the proposed NOAEL while
others thought the study to be flawed and
inappropriate.
?
The issue of using Tyl
(1991) has been discussed
in the OPP’s Hazard
Identification Assessment
Review Committee
(HIARC). HIARC
considered this is a good
study with appropriate
exposure duration for the
study scenarios.
OPP Questions to SAP
SAP RECOMMENDATIONS to OPP
6.
Please comment on whether the
significant non-systemic dermal effects
from dermal exposure to inorganic
chromium should form the basis of
dermal residential risk assessments, and,
if so, how the Agency should establish a
dermal endpoint for such an assessment.
!
7.
Please comment on whether OPP’s
choices of central tendency and high end
values for different parameters should,
collectively, produce estimates of the
middle and high end of the range of
potential exposures. If the Panel thinks
that OPP’s approach may not estimate
the high ends of the exposure range
(because it produces values that are either
higher or lower than the upper end of the
exposure range), please comment on
what specific values should be modified
to produce estimates of the high end of
potential exposure.
! Particularly when using point estimates it is important
to do subset analyses for specific regions of the country
(for example, the South compared to the North or
Midwest) and for age groups (for example, one year
olds compared to 5-6 year olds).
! The averaging of exposure over a 75-year lifetime may
underestimate risk. More research is needed to
understand the uncertainty associated with this form of
temporal averaging.
! More research is needed on the amount of soil ingested,
as this is still a source of uncertainty.
! For fully evaluating high end exposures it would be
necessary to include exposure of children with Pica.
! A probabilistic assessment as discussed in question 8 is
recommended.
EPA should base risk assessments for noncancer health
effects of dermal exposure to hexavalent chromium on
direct dermal effects irritant and allergic contact
dermatitis
OPP RESPONSE
?
Because the thresholds
for the dermal effects
usually are very low and
individual variations
usually are big, therefore,
the dermal effects will be
address in a qualitative
risk assessment.
? OPP will conduct a
probabilistic risk
assessment which will
include regional and
seasonal subset analyses.
? 75- years old lifetime is
recommended by the EPA
Exposure handbook which
has been presented to the
SAP in 1999.
? OPP/ORD used more
updated data from Stnek
and Calabrease (2000) and
Stanek et al. (2001) and a
workshop report by
ATSDR on soil pica
workshop (ATSDR, 2001)
? The probabilistic risk
assessment will address
the issue of children with
Pica.
OPP Questions to SAP
SAP RECOMMENDATIONS to OPP
OPP RESPONSE
8. Please comment on whether the existing
data bases on the variability of the
different parameters affecting potential
exposure are adequate to support the
development of probabilistic estimates of
potential exposure. If the Panel regards
the data bases as adequate for that
purpose, please identify which parameters
should be addressed using a distribution
of values and which data bases should be
used to supply the distribution for
particular parameters.
! In view of its concerns that the deterministic model
reviewed in Question 7 will not correctly estimate the
central tendency or percentiles of the exposure
distribution, the SAP recommends that the EPA
immediately begin to take steps toward the
development and progressive refinement of
probabilistic models of exposure. The probabilistic
models will give high-end values that are interpretable
as a percentile of the modeled exposure distribution
rather than a biased approximation of the upper limit of
exposure. The existing databases on the variability of
the different parameters affecting potential exposures of
children using CCA-treated playground structures are
adequate to begin the development of probabilistic
estimates of potential exposure provided the
uncertainty associated with these data is reflected in the
exposure modeling. As noted above, the Panel views
the development of a probabilistic assessment as a
process of progressive learning and refinement. New
or more detailed data on states and transition factors are
needed and will contribute to improvements in the
exposure models as they become available.
? Based on the panel
recommendation, EPA has
already started to develop
a probabilistic risk
assessment using the
SHEDS-Wood model.
? OPP agrees with the SAP
panel recommendations in
regards to the
development of the
probabilistic risk
assessment. The panel
recommendations will be
incorporated into the
development of the risk
assessment for CCA.
OPP Questions to SAP
SAP RECOMMENDATIONS to OPP
OPP RESPONSE
9. OPP is assuming that a one-to-one
relationship applies to the transfer of
residues from wood to skin. The Panel is
asked to address whether this is a
reasonable assumption, and if not, to
provide guidance on other approaches.
! The Panel does not recommend assuming that a one-toone relationship applies to the transfer of CCA
chemical residues from wood to skin as proposed by
the Agency. It is the Panel’s opinion that the
underlying conceptual model is questionable.
Sufficient justification for a one-to-one relationship
was not provided and the limited available empirical
data contradict the validity of the assumed one-to-one
relationship.
! The Panel strongly recommends that the Agency
expand its planned joint study with CPSC to measure
dislodgeable CCA chemicals from an appropriate
sample of play structures, so as to obtain information of
more direct value for exposure assessment. Ideally
CCA chemical loadings on the hands (and possibly
other skin surfaces) of children using play structures
would be measured in addition to corresponding
dislodgeable residues. At a minimum, some Panelists
would accept gathering of data sufficient to more
adequately support implementation of OPP’s current
conceptual model (e.g., matched adult volunteer hand
and cloth wipe samples to better establish the
relationship between these two measures as well as the
constancy of any relationship as a function of surface
area sampled).
! The Panel was divided on an interim recommendation
for the Agency while it awaits collection of these
additional data for the EPA/CPSC study. Some Panel
members were willing to endorse interim use of
existing hand or fabric wipe data if described
probabilistically. One Panel member voiced strong
opposition to any use of cloth wipe data until the
Agency obtained additional information establishing
? OPP agrees with the panel
approach related to this
question and will follow
their recommendations for
the development of the
risk assessment.
? A new transfer efficiency
based on ACC (2003) and
CPSC (2003) studies had
been developed for
probablistic assessment.
OPP Questions to SAP
10.
The Panel is asked to comment on
whether the proposed Soil Adherence
Factor (AF) of 1.45 mg/cm 2 for hand
contact with commercial potting soil is
a realistic value for use in estimating the
transfer of residues from playground
soil to skin in this assessment.
SAP RECOMMENDATIONS to OPP
! Use of an AF of 1.45 mg/cm2 is not recommended.
The proposed AF was derived from an unpublished
study of very limited scope. EPA has funded
subsequent research to derive more representative
values.
OPP RESPONSE
? OPP agrees with the panel
and will use the study
conducted by Holmes et.
Al. (1999) based on
lognormal distribution, a
geometric mean of 0.11
mg/cm2 and a geometric
standard derivation of 2.0
was selected.
? The probabilistic risk
assessment will address
the seasonal and
geographic variations.
OPP Questions to SAP
11.
OPP will need to calculate intermediateterm, and possibly long-term exposures
in this assessment using available
wood/soil residue data. The Panel is
asked to recommend a credible approach
for selecting residue data values for use
in OPP’s risk assessment, taking into
consideration the inherent variability of
the data sets. Please advise us on
which values are best for representing
central tendency and high end
exposures. Also, the Panel is asked to
discuss the feasibility of combining data
from individual data sets.
SAP RECOMMENDATIONS to OPP
OPP RESPONSE
! The proposed USEPA/CPSC study of wood and soil
residues associated with CCA-treated playground
equipment provides a unique opportunity to generate a
substantial data set on the variability of residue levels
for the playground scenario using a standardized
sampling and analytical methodology. This study
should help to resolve uncertainty regarding the relative
contribution of true, inherent variability in residues
versus variability due to differences in methodology. It
is critical, therefore, that the protocol be highly detailed
regarding sampling methods, locations, and frequencies
and that the protocol be rigidly followed. Basic
scientific criteria for acceptance of the final data set
should be laid out first and include: standardized
collection methods, precision, accuracy,
reproducibility, and other measures of QA/QC.
! The Agency should not combine data with quite
differing levels of precision and conservativeness, and
use one set of data to drive other model considerations.
The model cannot be fully evaluated without real world
(i.e., biomonitoring or soil consumption) data for
comparison, and that comparison cannot be made
without a representation of both variability and
uncertainty in model outputs.
? OPP followed the panel
recommendations and
obtained pertinent data
from the sampling study
conducted in cooperation
with the CPSC.
? The CPSC’s wood residue
study (2003) was
combined with ACC’s
(2003) study for the
surface residue
concentration distribution
OPP Questions to SAP
12. Does the Panel have any
recommendations for combining the four
scenarios (oral/wood, dermal/wood,
oral/soil, dermal/soil) such that a realistic
aggregate of these exposure routes may
be estimated?
SAP RECOMMENDATIONS to OPP
!
!
!
The Panel encourages the Agency to aggregate
exposure estimates across all potential sources. This
should occur in a way that makes the contribution of
various sources of exposure transparent and tracks
separate species of arsenic and chromium. Although
data at present are limited, it is possible that the
different species of arsenic encountered from distinct
exposure scenarios may differ with respect to their
hazard. For example, arsenic in the form of a complex
of copper chromated arsenate ingested from direct
contact with freshly treated wood might be
metabolized and excreted differently than arsenate
leached from weathered wood and ingested
incidentally in soil.
The suggested scenarios (oral/wood, dermal/wood,
oral/soil, dermal/soil) capture the exposures that may
occur on playscapes and decks. Inhalation exposure
may be a route that should be included, however at this
point in time, data are insufficient to estimate the
distribution of possible inhalation exposures. Refer to
the response to question 13 for further analysis.
However, in terms of the aggregate exposure
assessment, the proposed scenarios do not capture
sources of exposure that appear to be significant. The
Panel suggests that the Agency broaden its inquiry to
consider the diversity of possible exposures to arsenic,
chromium and copper. Some Panel members felt that
the Agency should expand its formal analyses of
exposure to include other media under the jurisdiction
of other EPA offices— drinking water, air, and
waste— to avoid a fragmented and incremental
approach to risk assessment and management of
arsenic, chromium and copper species.
OPP RESPONSE
?
?
?
?
After the completion of
the probabilistic
modeling, OPP had
combined the results
from the four scenarios to
obtain an aggregate risk
assessment.
OPP believes that the
probabilistic modeling
will answer most of the
panel’s questions in
regards to this issue.
OPP agree that inhalation
route should not be
included.
OPP agree with panel’s
recommendation and look
at into EWG’s raw data
as consideration.
OPP Questions to SAP
Question 12 (Continued)
SAP RECOMMENDATIONS to OPP
OPP RESPONSE
Probabilistic methods should be used to estimate
exposure and risk. This demands selection of best
available data sets to construct distributions. This
must be done with considerable care. The EWG
approach seems conceptually reasonable; however,
their method combines point estimates with
distributions, and this may introduce bias into the
estimates. The Lifeline method is especially well
adapted to aggregate exposures across diverse routes,
while preserving estimates at the level of the
individual. The Agency should be encouraged to
develop this model in the immediate future while
closing data gaps.
?
!
Uncertainty should be carefully characterized,
distributions characterized, and clear criteria applied to
judge the quality of available data for each parameter
included in the assessment. The Agency should
further develop Table 4 in the EPA support document
Children’s Exposure to CCA Treated Wood
Playground Equipment and CCA Contaminated Soil.
Table 8 in the Gradient Corporation submission
provides a similar model that attempts to identify
ranges of factors potentially affecting exposure, tracks
the sources of data, and provides a preliminary
characterization of uncertainty.
?
!
Regarding uncertainty and default assumptions the
Agency should confront two questions directly: When
are data of sufficient quality to include in a modeling
effort? What should be done until data are adequate?
The SAP provided the Agency with clear criteria to
judge data quality in 1999, and these were recognized
!
?
?
Uncertainty analysis was
conducted based on 2stage Monte Carlo
simulation.
In SAP 2002, OPP and
ORD had develop the
method including warm
and cold climate (see
SHED-Wood report,
2003).
OPP agree with panel’s
comments, the childhood
behavior and activity data
are needed.
In SHEDS-Wood, the age
is considered in the
simulation
OPP Questions to SAP
Question 12 (Continued)
SAP RECOMMENDATIONS to OPP
?
The Agency should develop methods that aggregate
exposure and risk estimates for individuals. These
may then be aggregated by various demographic
characteristics— age, income, ethnicity, and location
(north/south; urban/rural), or specific behavioral
characteristics.
?
The literature on childhood behavior and activity
patterns that may be associated with CCA exposures is
quite young. It provides only a limited basis for
understanding the associations between behavior and
exposure. The Panel recommends that the Agency
undertake studies of childhood behavior and activity
patterns to clarify these possible associations, as
children move through their daily life. These studies
would be useful in EPA assessment of exposures to
many different hazardous substances. The Agency’s
efforts in developing the Exposure Factors Handbook
and the more recent Children’s Exposure Factors
Handbook are very positive and important
contributions that support data based, behavioral
scenario-building.
?
The Panel anticipates considerable year-to-year
variability in exposure among children ages 1-6.
Toddlers between 1 and 2 years of age play, behave,
eat and dress very differently than 6 year olds, and
these are likely to affect contact with contaminated
media.
?
CCA-treated wood is increasingly being used for
interior construction, and if unfinished and left
OPP RESPONSE
OPP Questions to SAP
Question 12 (Continued)
SAP RECOMMENDATIONS to OPP
?
?
Residential, educational, day-care, recreational, and
occupational environments all offer the possibility of
childhood exposures to CCA. Specific locations where
CCA is in common use include decks, playscapes,
railings, docks, piers, pilings, fencing, and exposed
untreated interiors of structures, especially those close
to the ground such as sills. Picnic tables, mulch, and
contact with wood scraps, smoke from intentional and
unintentional fires, and ashes from burned construction
debris could all be sources of exposure.
The Panel encourages the Agency to consider possible
high exposure scenarios defined by overlapping risk
factors. For example, a toddler living in the
Southwest, may experience high drinking water
concentrations of arsenic. At the same time the warm
climate encourages extended periods of outdoor
recreation. If this child is enrolled in a day care
facility with decks and play structures made from
CCA-treated wood, the aggregate exposure may be
high. The identification of populations that are both
physiologically susceptible and highly exposed would
provide a logical basis for strategic risk management.
OPP RESPONSE
?
SHED-Wood focus on
children 1-6 year old to
public playset in daycare
center, and should be the
primary focus. The
exposure to the home
playset is considered as
secondary scenarios.
?
OPP agree panel’s
comments it will be
helpful if a biomonitoring
study can be conducted,
such as in South west
area.
OPP Questions to SAP
13. Can the Panel comment on whether OPP
should conduct a child playground
inhalation exposure assessment, taking
into consideration the hazard profile for
chromium (VI) as an irritant to mucous
membranes? If so, can the Panel
comment on whether the endpoint
described above is appropriate for
assessing the risk to children from such
an exposure?
SAP RECOMMENDATIONS to OPP
!
!
The Panel notes that both the trivalent and hexavalent
forms of chromium are of concern in the inhalation
route of exposure and that arsenic should also be
considered in the inhalation route of exposure.
However, the Panel agrees that calculations of
probable exposure concentrations suggest that the
Agency should not consider the inhalation route of
exposure to inhaled metals in their risk assessment.
The SAP strongly suggests, however, that exposure
concentrations be monitored via personal and area
sampling to validate such a conclusion.
OPP RESPONSE
?
Opp does not have a plan
to perform inhalation
exposure assessment.
?
In General, OPP assumes
that because of the low
volatility of the CCA,
conducting an inhalation
study is not possible.
However, OPP will try
to obtain any data
available related to the
inhalation of CCA
OPP Questions to SAP
14. Data on the effectiveness of reducing
exposure by using buffering materials are
limited. Does the Panel have
recommendations as to whether
additional studies to obtain this
information are warranted? Does the
Panel have suggestions on how OPP can
best evaluate child exposures attributed
to contact with CCA-contaminated
buffering materials?
SAP RECOMMENDATIONS to OPP
!
The consensus of the Panel is that additional studies
are warranted to obtain information needed to assess
the exposures associated with using buffering
materials.
!
Buffering materials do not appear to provide a means
to reduce exposures to CCA leached from play
structures. Rather, buffering materials can present
important risk scenarios that differ from the four
scenarios currently proposed for analysis by the
Agency. These additional scenarios include: 1)
exposure to buffer materials that become contaminated
with metals from CCA leached from play structures
and 2) exposure to buffer materials that contain CCA
because they consist of recycled
construction/demolition debris which contains CCAtreated wood.
!
Exposure to buffer materials that become contaminated
with metals from CCA needs to be examined. This
effort should be aided by the generation of data
describing the amount and nature of exposure in young
children who play on or with these materials. It may
also be possible to generate bounding estimates of
exposure from these materials for the purpose of
screening the relative importance of this scenario
compared to other play structure-related scenarios.
!
Exposure to buffer materials that contain CCA-bearing
mulch will likely result in a sufficient hazard potential
to warrant a modification of the recycling practices
that lead to the introduction of this mulch into
children's play environments.
OPP RESPONSE
?
OPP agrees that there is a
need for further studies.
?
OPP will try to obtain all
available data related to
buffers and the extent of
the contamination of
buffers used in CCAtreated playgrounds.
OPP Questions to SAP
15. The Panel is asked to comment as to
whether stains, sealants and other coating
materials should be recommended as a
mitigation measure to reduce exposure to
arsenic and chromium compounds from
CCA treated wood. If so, can the Panel
SAP RECOMMENDATIONS to OPP
!
!
!
!
!
!
!
.
The Panel recommends that the EPA inform the public
of the ability of certain coatings to substantially reduce
leachable and dislodgeable CCA chemicals and thus
reduce potential exposure to arsenic and chromium.
While the Panel makes recommendations below
regarding the need for additional studies in this area, it
feels that the current evidence is sufficient to begin
advising the public about the use of coatings now.
The weight-of-evidence from available studies
indicates that certain
Reductions of 70 to 95% in dislodgeable arsenic
were seen in all studies that subjected CCA wood
to natural weathering.
There is no evidence that water repellants added
directly to the CCA treatment solution are effective
in reducing leachable/dislodgeable CCA chemicals.
Confidence is highest for polyurethane as this
coating has been shown to result in substantial 70
to >95% reduction in dislodgeable arsenic in a well
controlled field study, a “real-world” application
allowing for effects of use, and a short-term
controlled laboratory study.
Current data support a treatment frequency of once
per year, although for some products this may be
too frequent (e.g., possibly polyurethane where one
study noted up to 95% reduction in dislodgeable
arsenic out to 2 years). This is an area in need of
additional study.
More studies are needed to evaluate the
performance / efficacy of different types and brands
of coatings.
OPP RESPONSE
?
The Agency is looking
into this issue and is
considering the panel’s as
well as the industry’s
recommendations for the
most appropriate way to
advise the public for
suitable sealants to be
used on the CCA-treated
wood.
?
SHEDS-Wood used
average 90% as reduction
factor (from existing
articles) and assuned 99.5
as maximum effect
sealant in the simulation
Appendix G
Effect of Hand Washing on Risks from
Exposure to Residues
Effect of Hand Washing on Risks from Exposure to Residues
November 7, 2003
The effect of hand washing on risk from residue only exposure was examined. Two
pathways, dermal absorption and ingestion, were summed to determine the risk due to residue
only exposure. Comparisons were then made for this residue risk between baseline and the hand
washing mitigation scenario for playsets alone and deck and playset exposure. Results are
presented in bar charts for the 50th and 95th percentiles. The results at the 99th percentile are
somewhat unstable so they are not presented. Figure 1 is for playset only exposure and Figure 2 is
for playset and deck exposure. For playset only exposure, residue risks with hand washing were
reduced by approximately 36% at the median and slightly more (48%) at the 95th percentile. For
playset and deck exposure these differences are less. At the median, playset and deck residue risk
under baseline conditions were reduced by approximately 27%; at the 95th percentile they were
reduced by 35%.
When total risk is calculated by combining residue and soil risk the effect of hand washing
is less. Table 1 shows a comparison for total risk between baseline and the hand washing
mitigation scenario. For playset only exposure the difference between baseline and hand washing
at the 50 th and 95th percentiles is 32% and 45%, respectively. For playset and deck exposure, risks
are reduced by 22% and 29% at these same percentiles. See Zartarian et al. (2003) for a more
complete description of the hand washing scenario.
Figure 1. Comparison of Playset Only Residue Risk for Baseline and Hand Washing
1.5E-04
1.4E-04
Baseline
1.3E-04
Hand Wash
1.2E-04
1.1E-04
1.0E-04
Cancer Risk
9.0E-05
8.0E-05
7.0E-05
6.0E-05
5.0E-05
4.0E-05
3.0E-05
2.0E-05
1.0E-05
0.0E+00
50%ile
95%tile
Figure 2. Comparison of Playset and Deck Residue Risk for Baseline and Hand Washing
1.5E-04
1.4E-04
Baseline
1.3E-04
Hand Wash
1.2E-04
1.1E-04
1.0E-04
Cancer Risk
9.0E-05
8.0E-05
7.0E-05
6.0E-05
5.0E-05
4.0E-05
3.0E-05
2.0E-05
1.0E-05
0.0E+00
50%ile
95%tile
Table 1 Comparison for Total Risk (Residue and Soil) Between Baseline
and the Hand Washing Mitigation Scenario
50th Percentile
95th Percentile
Baseline
1.10E-05
8.30E-05
Hand Wash
7.50 E-06
4.60E-05
32%
45%
50th Percentile
95th Percentile
Baseline
2.30E-05
1.40E-04
Hand Wash
1.80E-05
1.00E-04
22%
29%
Total Risk:Playset Only
Percent Reduction
Total Risk: Playset and Deck
Percent Reduction